With no explanation, chose the best option from "A", "B", "C" or "D". unless it could sue the Group.” Id.; Salido v. Allstate Ins. Co. (N.D.Cal.1999), No. C98-04616CRB, 1999 WL 977944. {¶ 56} Regardless, other states have also recognized this management theory as a basis for liability when there is no privity of contract and as an alternative to using the doctrine of piercing the corporate veil. See Dellaira v. Farmers Ins. Exchange (2004), 136 N.M. 552, 102 P.3d 111 (“[w]e conclude that Plaintiffs stated a claim for breach of duty to act in good faith, and that, under some state of facts, relief might possibly be granted. Because the matter before us is one of first impression, we do not fault the district court in following the usual doctrine of lack of contractual privity”); Gatecliff v. Great Republic Life Ins. (1991), 170 Ariz. 34, 821 P.2d 725 (<HOLDING>); Williams v. Farmers Ins. Group, Inc.

A: recognizing strict product liability actions
B: holding that an insurance contract between the parties and a breach thereof by the defendant is an element of a bad faith refusal claim
C: recognizing a direct liabilitymanagement theory and explaining that  under these circumstances strict adherence to the general rule that liability for bad faith breach may be imposed only against a party to an insurance contract would permit farmers to shield itself from liability through the device of a management company 
D: holding title company liable for bad faith
C.