In which of the following types of action, brought against a CPA who issues an audit report containing an unqualified opinion on materially misstated financial statements, may a plaintiff prevail without proving reliance on the audit report?
1) An action for common-law fraud.
2) An action for common-law breach of contract.
3) An action brought under Section 11 of the Securities Act of 1933.
4) An action brought under Rule 10b-5 of the Securities Exchange Act of 1934.