A lawyer has a duty to a nonclient third party only if the client’s intent to benefit that third party (in the way the third party asserts in their malpractice claim) is “clear,” “certain” and “undisputed.”  Signs of the client’s intent do not meet that high standard if there is ground for dispute as to whom the client wished to benefit or what the client’s instructions to the lawyer were.  Here, a now deceased grandparent changed her testamentary trust to disinherit one of her son’s children.  She then formed three LLCs to hold property and made her sons members of the LLCs.  The LLCs’ operating agreements did not bar the sons from giving their membership interests to their children.  This decision holds that just disinheriting the one son’s children in the trust was not a clear, certain and undisputed indication that the grandparent wished to disinherit those grandchildren as to all future transactions.  So the defendant lawyers owed the other sons and their children no duty of care to assure the LLC membership interests couldn’t be passed to the disfavored grandchildren.