False representations made recklessly and without regard for their truth in order to induce action by another are the equivalent of misrepresentations knowingly and intentionally uttered. Yellow Creek Logging Cor v. Dare, 216 Cal.App.2d 50, 55 (1963), Engalla v. Permanente Medical Group, Inc., 15 Cal.4th 951, 977 (1997).
A misrepresentation may be a false representation of material fact or concealment or nondisclosure of material fact. Lazar v. Superior Court, 12 Cal.4th (1996) at 638.