Huggins's identity was stolen by an unknown person, who used it to obtain credit cards from various banks in Huggins's name. Huggins suffered the grief of cleaning up the identity theft. He sued the banks and credit card companies for negligence for issuing credit cards without more verification of the identity of the applicant and for failing to adopt other policies to prevent successful identity theft. Do the banks have a duty to protect potential victims of identity theft from imposter fraud? [Huggins v. Citibank, N.A., 585 S.E.2d 275 Sup. Ct., S.C. (2003)]