What is the test for determining whether a vendor created a risk of harm by marketing a fraudulent product?

Plaintiffs argue that the case of American Philatelic Society v. Claibourne (1935) 3 Cal.2d 689 [46 P.2d 135] (Claibourne) illustrates the appropriate focus on whether a defendant created a risk of harm rather than on strict tort causation. But [24 Cal. Rptr.3d 675] the Claibourne case did not dispense with the element of a causative link. Also, it is distinguishable from this case for several reasons. It was an action by competing vendors against a defendant who marked and perforated official postage stamps so that they resembled rare and expensive collectible stamps. ( Id. at p. 692.) Although defendant marketed the stamps to dealers as having unofficial separation, he told the dealers they could realize a handsome profit by reselling the misleading stamps. ( Id. at pp. 694695.) The court determined that defendant's marketing solicitation was susceptible to the inference that dealers could make large profits by reselling the counterfeit stamps as genuine government perforated stamps. ( Id. at p. 695.) The court stated that if defendant obtained a higher price for the stamps that was due to the possibility of the stamps' being palmed off as genuine, he had obtained an advantage grounded in fraud and deceit and secured a benefit to himself to which he is not in honesty and fair dealing entitled. ( Id. at p. 696.)