https://law.justia.com/cases/new-york/court-of-appeals/1931/255-n-y-170-174-n-e-441-1931.html classic 1931 decision creating the economic loss rule. Benjamin Cardozo argued that if all downstream economic harms caused by an action incurred liability, this would impose indefinite obligations on everyone. it's like a butterfly effect; you can't possibly be expected to foresee all the consequences of your action that might cause someone to lose money.