The American Law Institute Restatement of Torts states that a person injured by a fraudulent representation can recover from the maker only if the maker desired this injured person to rely on the representation. The maker's liability is further limited to those injuries arising from transactions in which the maker desired to influence the injured person.
Michigan Law Review,
FRAUDS - ACTIONS - PROPER PARTY PLAINTIFF,
Mich. L. Rev.
Available at: https://repository.law.umich.edu/mlr/vol37/iss7/7