The plaintiff operated a cattle farm in Iowa. When it considered using an anaerobic digester to dispose of manure on the farm it contacted a corporation specializing in the design and construction of anaerobic digesters to discuss the feasibility of installing a digester on its farm. Because the farm’s manure would not be enough to operate the digester, the corporation calculated that a digester would be economically feasible based upon the availability of 1,000 cubic feet of manure and 250 tons of paper sludge per day. The corporation also agreed to prepare a USDA grant application for the farm. In so doing, it hired an independent consultant to review the technical report and provide an opinion and recommendation. The independent consultant, which did not have a contract with the farm, composed a certification letter and performed an independent review required by the USDA grant application process. The letter stated that the project was “technically viable.” The farm was awarded the grant in 2008, and the corporation completed construction and installation of the digester. The digester never worked as planned, and the farm stopped using it within 6 to 8 months. The farm sued both the corporation and the independent consultant, ultimately settling with the corporation. The district court granted summary judgment to the independent consultant, finding that it was not “manifestly aware” that the farm would rely on its certification letter in deciding whether to build a digester. It also found that the farm had not actually relied on the letter. In affirming the judgment, the court ruled that the farm could not establish that it justifiably relied on any statements from the independent contractor because it made no statements with respect to the digester that the farm actually built. The farm used a different size and a substantially different substrate mixture than what had been proposed to the independent contractor. These factors were the most important features of a digester. The independent contractor made no representations as to the final design and could not be liable. Amana Society, Inc. v. GHD, Inc., No. 12-3515, 2014 U.S. App. LEXIS 13170 (8th Cir. Jul. 11, 2014).