Although there was no remedy for negligent misrepresentation at common law, and English law apparently still provides none, the American courts have all, in one way or another, accepted the thesis that "conscience, fair dealing and the usages of business require" some type of liability. But the nature and limits of that liability have never been clearly defined by the majority of American jurisdictions.
June W. Wiener, Negligent Misrepresentation: Fraud or Negligence, 13 Clev.-Marshall L. Rev. 250 (1964)
Fraud and Deceit (A Symposium)