In a Common Law Action Against an Accountant, Lack of Privity

In a common law action against an accountant, lack of privity is a viable defence if the plaintiff

A) Is the client's creditor who sues the accountant for negligence.
B) Can prove the presence of gross negligence that amounts to a reckless disregard for the truth.
C) Is the accountant's client.
D) Bases the action upon fraud.