Answering a question left open in Robinson Helicopter Co. v. Dana Corp. (2004) 34 Cal.4th 979, this decision holds that a plaintiff may assert a fraudulent concealment cause of action based on conduct occurring in the course of a contractual relationship if the elements of the claim can be established independently of the parties’ contractual rights and obligations, and the tortious conduct exposes the plaintiff to a risk of harm beyond the reasonable contemplation of the parties when they entered into the contract.