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Key’s claim that we must look to the underlying contract documents is incorrect, as the Supreme Court has recognized that a cause of action based upon an independent legal duty is a tort action. See Gutierrez v. Winnipeg Fire & Marine Ins. Co., 254 F.3d 743, 753 (7th Cir.2001); Sears, Roebuck & Co. v. Enco Commc’ns Inc., 43 N.Y.2d 389, 402-03, 401 N.Y.S.2d 73, 374 N.E.2d 126 (1978); Williams v. A.P. Green Refractories, Inc., 124 N.C.App. 633, 477 S.E.2d 161, 165 (1996); Restatement (Third) of Torts: Products Liability § 12 (1998) („A plaintiff can maintain a tort action in which recovery is based upon the existence of a legal duty owed by the defendant to the plaintiff.”); id. § 13; id. § 14; id. § 14 cmt. c („[I]f a duty exists by the law or by a promise, the fact that the defendant also had a duty or duties to act in accordance with the law or in accordance with the promise does not create a defense to tort liability.”); id. § 18 („[P]arties can assume legal duties by contract even though the underlying conduct on which those duties are based is also subject to duty under the law.”); id. § 19 („[I]f a defendant owes a duty under the law to protect the plaintiff, the defendant has a duty to perform that obligation.”).
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In the case of contracts, the underlying legal duty to perform the contract is created by the contract, not by a legal duty imposed by the law independent of the contractual obligation. Thus, for example, a tort claim based on negligence or fraud arising out of a contract is a claim of breach of contract, not a tort claim.
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