As part of the cause of action for negligence, the plaintiff must show that the defendant actually had a duty not to expose the plaintiff to an unreasonable risk. One of the issues that requires further examination is how far the duty extends. This explores whether one has a duty to avoid causing mental disturbance to another, whether one has an affirmative duty to act, whether there is a duty to unborn children, and whether parties to a contract have a duty to parties not in privity.