Following the Supreme Court’s recent adoption of the “independent duty rule” (see Eastwood v. Horse Harbor Foundation, Inc., 170 Wn.2d 380, 241 P.3d 1256 (2010) and Affiliated FM Insurance Co. v. LTK Consulting Services, Inc., 170 Wn.2d 442, 243 P.3d 521 (2010)), plaintiffs’ attorneys have been seeking to expand tort-based allegations for economic losses […]