Dissenting Opinion by
BELL, Chief Judge.The “911 system” 1 is an emergency system intended by the General Assembly to enhance, in recognition of their paramount importance, the safety and well-being of the citizens of Maryland by ensuring that timely and appropriate assistance is rendered when the lives or property of those citizens are in imminent danger. Maryland Code (1957, 1997 Replacement Volume, 2001 Cum.Supp.) Article 41, § 18-101(a).2 Recognizing that a multiplicity of emergency telephone numbers exists throughout the State and, indeed, within any given county and that the telephone is the usual mode by which emergency assistance is summoned, § 18-101(b), and “concerned that avoidable delays in reaching appropriate emergency aid are occurring to the jeopardy of life and property,” § 18-101(e), to achieve this purpose, the General Assembly “establish[ed] the *505three digit number, 911, as the primary emergency telephone number for the State of Maryland and ... provide[d] for the orderly installation, maintenance, and operation of 911 systems within the State.” See § 18-101(e). In so doing, it “acknowledge[d] that the three digit number, 911, is a nationally recognized and applied telephone number which may be used to summon emergency aid and to eliminate delays caused by lack of familiarity with emergency numbers and by understandable confusion in circumstances of crisis.” See § 18-101(d).
The 911 system is required, in an enhanced form,3 in all counties and Baltimore City after July 1, 1995. See § 18-102(a). The service through the system must include police, fire fighting, and emergency ambulance services and, at the discretion of the county or counties being served by the system, other emergency and civil defense services. See § 18-101(c). While a public safety agency whose services are available on the 911 system may maintain a separate secondary backup number for emergency calls, § 18-102(d), “[a]ny educational information relating to emergency services made available by the State or a county shall designate the number 911 as the primary emergency number,” even though it also may include a separate secondary backup number for emergency calls. See § 18-101(e). It thus is very clear that 911 is the option to be promoted for emergencies. More telling, competition with the 911 system simply is not permitted. Md Code (1999) § 15-126(c)(1) provides:
“(c) Insurer prohibited from engaging in competition with 911 emergency system.—
“(1) An entity subject to this section may not establish or promote an emergency medical response and transporta*506tion system that encourages or directs access by an insured or enrollee in competition with or in substitution of the Maryland Emergency Medical Services System (911) or other State, county, or local government emergency medical services system.”
The system is not free. The General assembly authorized a 911 fee, 10 cents per month payable at the time when the bills for telephone service are due, to be paid by the subscribers to 911-accessible service, including switched local exchange access service and wireless telephone service, § 18-105(b)(l), to be included in a 911 Trust Fund, out of which are to paid reimbursements to the counties for enhancements to a 911 system and expenditures to contractors in accordance with the provisions of § 18-103(h)(11). See § 18-105(a). It also authorized:
“(c)(1) In addition to the 911 fee imposed by [§ 18-105(b)(1) ], the governing body of each county [to] by ordinance or resolution after public hearing enact or adopt an additional charge not to exceed 50 cents per month to be applied to all current bills rendered for switched local exchange access service, wireless telephone service, or other 911-accessible service within that county. The amount of the additional charge may not exceed a level necessary to cover the total amount of eligible operation and maintenance costs of the county.”
Section 18-105(c)(l).
The 911 emergency system handles emergency calls for police, fire, and medical assistance and it is designed to do so in a more efficient and expedient manner. Thus, while not the police department or the emergency care provider, it provides a more limited, but nonetheless important, function, “as a clearinghouse for all emergency calls for assistance.” Elvera Trezzi v. City of Detroit, 120 Mich.App. 506, 328 N.W.2d 70, 74 (1982)(Benson, J., dissenting). Because established for the purpose of ensuring the provision of emergency assistance to the public, it is logical, as one court has opined, to assume that “once a municipality receives a call for help through the 911 *507system, it is obligated to perform in a proper and reasonable manner”; “ ‘that by accepting the call and agreeing to respond, the municipality had now narrowed a public duty to a special duty to that individual.’ ” Merced, Administratrix v. City of New York, 142 Misc.2d 442, 444, 534 N.Y.S.2d 60, 61 (Sup.Ct.1987), quoting Comment, “911” Emergency Assistance Systems, 8 Geo. Mason L. Rev 103,121 (1985).
Like the Court of Special Appeals, noting the integral link between the 911 operator’s duties and the delivery of emergency services, citing Fried v. Archer, 139 Md.App. 229, 257, 775 A.2d 430, 446, cert. granted, 366 Md. 246, 783 A.2d 221 (2001), the majority holds that “ ‘it is appropriate to measure’ [the 911 operators’] negligence liability, as well as the liability of their managers and supervisors, ‘by the same standard applied to the police officers who respond to their dispatches.’ ” Muthukumarana v. Montgomery County, 370 Md. 447, 489-90, 805 A.2d 372, 397-98 (2002), quoting Fried, 139 Md. App. at 257, 775 A.2d at 446. That standard is embodied, it concludes, in the “public duty doctrine.” Under that doctrine, the majority explains:
“when a statute or common law “imposes upon a public entity a duty to the public at large, and not a duty to a particular class of individuals, the duty is not one enforceable in tort.” Dan B. Dobbs, Tub Law Of Touts § 271 (2000) (footnote omitted). As we explained in Ashburn [v. Anne Arundel County, 306 Md. 617, 510 A.2d 1078 (1986) ] the “duty owed by the police by virtue of their positions as officers is a duty to protect the public.” Ashburn, 306 Md. at 628, 510 A.2d at 1084. Pursuant to the doctrine, therefore, police officers ordinarily may not be held liable for failure to protect specific persons because they owe no duty, as the first element of a negligence action requires, to those individuals.”
Id. at 486-87, 805 A.2d at 395-96 (footnote omitted).
Accordingly, the majority also holds that “absent a special relationship between a 911 employee and an individual in need of the telephone services, an employee does not owe such an *508individual a private duty in tort,” id. at 486, 805 A.2d at 395, and, consistently with courts in other States,4 that “the legal duty owed by 911 employees ‘by virtue of their position, is [also] a public duty to aid.’ ” Id. at 490, 805 A.2d at 397-98.5 More particularly, the majority states:
“Pursuant to the public duty doctrine, therefore, a 911 employee generally owes no duty in tort for the negligent performance of his or her duties to an individual in need of emergency telephone services.... [T]he special duty rule limits the applicability of this doctrine. Specifically, if an individual plaintiff establishes that a 911 employee owed him or her a special duty, based on the existence of a special relationship between the two, the employee may be found *509liable to the individual in tort for the negligent performance of his or her duties.”
Id. at 491-92, 805 A.2d at 398-99. Critical to the majority’s analysis is the absence of a duty owed by the 911 operators to the victims in these cases.
I agree that the crucial inquiry is whether there was a duty owed in these cases, for it is true that absent a duty of care, there can be no liability in negligence. See Walpert, Smullian & Blumenthal, P.A. v. Katz, 361 Md. 645, 655, 762 A.2d 582, 587 (2000). In West Va. Central v. Fuller, 96 Md. 652, 666, 54 A. 669, 671-72 (1903), we were explicit:
“[Tjhere can be no negligence where there is no duty that is due; for negligence is the breach of some duty that one person owes to another.... As the duty owed varies with circumstances and with the relation to each other of the individuals concerned, so the alleged negligence varies, and the act complained of never amounts to negligence in law or fact, if there has been no breach of duty.”
I do not agree, as the majority concludes, that no duty of care was owed by the 911 operators in these cases to the appellees and the respondents.6
*510In Maryland, establishment of a cause of action for negligence requires that a plaintiff prove: a duty owed to the plaintiff or to a class of which the plaintiff is a part; a breach of that duty; a causal relationship between the breach and the harm; and damages suffered. Katz, 361 Md. at 655, 762 A.2d at 587. See Jacques v. First Nat’l Bank, 307 Md. 527, 531, 515 A.2d 756, 758 (1986); Cramer v. Housing Opportunities Comm’n, 304 Md. 705, 712, 501 A.2d 35, 39 (1985); Scott v. Watson, 278 Md. 160, 165, 359 A.2d 548, 552 (1976); Peroti v. Williams, 258 Md. 663, 669, 267 A.2d 114, 118 (1970).
The first element is “duty,” the foundation of a negligence action and the predicate upon which such action is founded. Ashburn v. Anne Arundel County, 306 Md. 617, 627, 510 A.2d 1078, 1083 (1986). In negligence cases, “duty is always the same — to conform to the legal standard of reasonable conduct in the light of the apparent risk.” W. Page Keeton, Prosser and Keeton on The Law of Torts, § 53, at 356 (5th ed.1984). Analyzing this element, Judge Cole, for the Court, pointed out:
“ ‘Duty’ in negligence has been defined as ‘an obligation, to which the law will give recognition and effect, to conform to a particular standard of conduct toward another.’
*511There is no set formula for this determination. As Dean Prosser noted, ‘duty is not sacrosanct in itself, but is only an expression of the sum total of those considerations of policy which lead the law to say that the particular plaintiff is entitled to protection.’ ... In broad terms, these policies include: ‘convenience of administration, capacity of the parties to bear the loss, a policy of preventing future injuries, [and] the moral blame attached to the wrongdoer....’ ”
Id. (quoting W. Page Keeton, Prosser and Keeton on The Law of Torts, § 53, at 164 (5th ed.1984)). See Brown v. Dermer, 357 Md. 344, 357, 744 A.2d 47, 54 (2000); Rosenblatt v. Exxon Co., U.S.A., 335 Md. 58, 76-77, 642 A.2d 180, 189-90 (1994); Erie Ins. Co. v. Chops, 322 Md. 79, 84, 585 A.2d 232 (1991); Jacques v. First Nat. Bank of Maryland, 307 Md. 527, 532, 515 A.2d 756, 758-59 (1986). “In other words, ‘duty’ is a question of whether the defendant is under any obligation for the benefit of the particular plaintiff.” Prosser and Keeton, supra, at 356. See Valentine v. On Target, Inc., 353 Md. 544, 550, 727 A.2d 947, 949 (1999).
Among the variables to be considered in determining whether a duty to another exists, we have said, are:
“the foreseeability of harm to the plaintiff, the degree of certainty that the plaintiff suffered the injury, the closeness of the connection between the defendant’s conduct and the injury suffered, the moral blame attached to the defendant’s conduct, the policy of preventing future harm, the extent of the burden to the defendant and consequences to the community of imposing a duty to exercise care with resulting liability for breach, and the availability, cost and prevalence of insurance for the risk involved.”
Ashburn, 306 Md. at 627, 510 A.2d at 1083, quoting Tarasoff v. Regents of University of California, 17 Cal.3d 425, 131 Cal. Rptr. 14, 551 P.2d 334, 342 (1976). Inherent also in the concept of duty is that there be a relationship between the parties, out of which the duty arises. Rosenblatt v. Exxon, 335 Md. at 77, 642 A.2d at 189. As among these, we have stated that the factor deemed most important is foreseeability, *512see id., although we have cautioned that “foreseeability” must not be confused with “duty,” noting:
“The fact that a result may be foreseeable does not itself impose a duty in negligence terms. This principle is apparent in the acceptance by most jurisdictions and by this Court of the general rule that there is no duty to control a third person’s conduct so as to prevent personal harm to another, unless a ‘special relationship’ exists either between the actor and the third person or between the actor and the person injured. See Lamb v. Hopkins, 303 Md. 236, 242-44, 492 A.2d 1297, 1300-01 (1985); Restatement (Second) of Torts § 315 (1965); Scott v. Watson, 278 Md. 160, 166, 359 A.2d 548, 552 (1976) (‘a private person is under no special duty to protect another from criminal acts by a third person, in the absence of statutes, or of a special relationship.’).”
Ashburn at 628, 510 A.2d at 1083.
Thus, “[i]n determining the existence of a duty owed to a plaintiff, we have applied a ‘foreseeability of harm’ test.” Rosenblatt v. Exxon, 335 Md. at 77, 642 A.2d at 189. To be sure, that test, like the relationship between the parties, is based upon the recognition that a duty must be limited to avoid liability for unreasonably remote consequences. They also serve to more clearly define whether there is a duty and the boundaries of that duty. It is not surprising, therefore, that this Court has acknowledged that a legal duty arises from “the ‘responsibility each of us bears to exercise due care to avoid unreasonable risks of harm to others.’ ” B.N. v. K.K., 312 Md. 135, 141, 538 A.2d 1175, 1178 (1988), quoting Moran v. Fabergé, 273 Md. 538, 543, 332 A.2d 11, 15 (1975). After all, “[t]he seriousness of potential harm, as well as its probability, contributes to a duty to prevent it.” Faya v. Almaraz, 329 Md. 435, 449, 620 A.2d 327, 333 (1993). See Baltimore Gas and Elec. Co. v. Flippo, 348 Md. 680, 700, 705 A.2d 1144, 1154 (1998).
I have not the slightest doubt that the 911 operators in these cases owed the victims in these cases a duty of care. As *513we have seen, by statute, each of the state’s twenty three counties and the City of Baltimore are required to have in place a 911 system, which automatically connects a person dialing 911 to an established public safety answering point, at which police, fire and emergency ambulance service may be accessed. The reason for the requirement, the General Assembly made clear, was to enhance the delivery of such services, to ensure that they were available more readily— accessed more easily — and that they be delivered more efficiently and expeditiously. In fact, in stating the purpose of the legislation, the Legislature pointedly expressed concern for the safety and well-being of the citizens of Maryland and that timely and appropriate assistance — it specifically and emphatically recognized the danger inherent in any delay — be available and provided when an emergency situation places the lives or property of those citizens in imminent danger. Moreover, the legislation provides that educational material regarding the system refer to 911 as the primary emergency number, thus further emphasizing its importance in the emergency response area.
The victims7 were citizens of Maryland faced with emergencies of the kind to which the 911 system is designed to respond. In each case, the victims’ lives were imminently at peril. In each case, the 911 system was utilized in an attempt to obtain appropriate emergency assistance, in a timely manner. In each case, the call was answered, not refused, and the operator was told of the emergency, but in neither instance was there a timely response, consistent with the emergency presented and reported. In each case, the victims suffered damage; in each instance, they died or were killed. In each case, this result was not only foreseeable, but, without immediate intervention, predictable.
The State having established, mandated, funded and provided oversight for a 911 system expressly for the purpose of *514preventing avoidable delays in the delivery of emergency services and to protect the lives and property of its citizens, neither it nor any of the counties or Baltimore City reasonably may contend that a 911 system does not owe a duty to a person who avails him or herself of that system, that something more than a call for assistance is necessary to create the special relationship required to permit recovery for damages incurred as a result of the 911 operator’s negligence. In fact, such a position is, to be quite blunt, nonsensical.
To be sure, perhaps neither the State nor any of the subdivisions were required to provide a 911 system; however, the State has chosen to do so and to impose the obligation on its subdivisions. Of course, when the choice was made to assume the 911 obligation, we have made clear, it carried with it the obligation to ensure that the obligation is discharged, or executed, in a reasonable manner. Ashburn, 306 Md. at 631, 510 A.2d at 1085. See Scott v. Watson, 278 Md. 160, 170-71, 359 A.2d 548, 555 (1976); Pennsylvania R.R. Co. v. Yingling, 148 Md. 169, 129 A. 36 (1925). Moreover, the system chosen invited, and, indeed, encouraged the citizens to utilize the system, holding out the promise that their calls for help would be promptly and efficiently handled, with the result that the potential losses precipitating the calls would be ameliorated or moderated. That invitation, encouragement and, most important, promise of an appropriate and timely response provide the predicate for a special relationship from which a duty flows. All that is required to finalize that relationship is a call from a citizen in need of, or on behalf of someone in need of, the assistance offered and promised. Austin v. City of Scottsdale, 140 Ariz. 579, 684 P.2d 151, 154 (1984) (failure to act immediately on an emergency call, even though it was anonymous); DeLong v. County of Erie, 60 N.Y.2d 296, 469 N.Y.S.2d 611, 457 N.E.2d 717, 721-22 (1983); Bratton v. Welp, 145 Wash.2d 572, 39 P.3d 959, 961 (2002); St. George. v. Deerfield, 568 So.2d 931, 932 (Fla.App.1990); Hancock v. City of New York, 164 Misc.2d 122, 623 N.Y.S.2d 63, 67 (N.Y.Sup.Ct.1994); Merced, Administratrix v. City of New York, 142 Misc.2d 442, 444, 534 N.Y.S.2d 60, 61 (Sup.Ct.1987). See In the Interest Of: J.B., 621 So.2d 489, 490-91 (Fla.App.1993) (“A *515911 call is a cry to the authorities for help. And until the investigating officer is reasonably satisfied that no emergency exists, he is within his legal duty to investigate such calls in a manner consistent with their emergency nature”).
DeLong was a wrongful death action brought by the estate of a woman who was killed by a burglar after she had called 911 and received assurances that help was being dispatched. It alleged that the call was negligently processed and, so, negligently responded to. The Court held that by creating a special service, accepting the call for emergency assistance and assuring the caller that help was on the way established a special relationship with, and duty to, the caller. 469 N.Y.S.2d 611, 457 N.E.2d at 721. What the Court of Appeals of New York had to say about the predicate for liability in DeLong is particularly apropos this case:
‘In this case the decision had been made by the municipalities to provide a special emergency service which was intended and proclaimed to be more efficient than normal police services. Those seeking emergency assistance were advised not to attempt to call the general number for the local police, which ironically might have avoided the tragedy encountered in this case, but were encouraged to dial the 911 number to obtain a quicker response. In addition, and most significantly, the victim’s plea for assistance was not refused. Indeed she was affirmatively assured that help would be there ‘right away’. Considering the fact that she was merely a block and a half from the local police station, and was not yet at the mercy of the intruder, it cannot be said as a matter of law that this assurance played no part in her decision to remain in her home and not seek other assistance. Unfortunately, it only increased the risk to her life.”
Id. 8
In Bratton, reversing the judgment of the intermediate appellate court, the Supreme Court of Washington explained *516the application of the public duty rule in that State, with particular emphasis on the reliance element:
“To establish [public duty] exception, the plaintiff must show that there is some form of privity between the plaintiff and the public entity that differentiates the plaintiff from the general public, that the public entity made an express assurance to the plaintiff, and that the plaintiff justifiably relied on the assurance. Privity should be construed broadly, and, in cases based on failure by the police to timely respond to requests for assistance, it refers to the relationship between the public entity and a reasonably foreseeable plaintiff.”
39 P.3d at 961.9
Similarly, with respect to incapacitated victims, it is the foreseeability of the harm and the victim that controls, not whether that victim specifically relied upon, or even knew of, the call to 911. See Merced, v. New York, 142 Misc.2d 442, 445-46, 534 N.Y.S.2d 60, 62 (Sup.Ct.1987) (“Realistically, an individual who is in dire need of assistance is often too incapacitated to call 911. It is therefore necessary to broaden the general rule so that any caller, who relies on the assurances of the municipality that they are on their way, created *517the requisite ‘special relationship’ required to hold a municipality liable.”); Lewis v. City of Indianapolis, 554 N.E.2d 13(1990).10 It is, I submit, the invitation to use the system and the holding out of the promise of assistance should the invitation be accepted that triggers reliance. Indeed, there is no reason for there to be a 911 emergency system, and certainly no reason to publicize it, if it was not intended that the citizens use it and rely on it.
The majority maintains that “in order for a special relationship between a 911 employee and a person in need of assistance to exist, it must be shown that the 911 employee affirmatively acted to protect or assist the specific individual, or a specific group of individuals like the individual, in need of assistance, thereby inducing the specific reliance of the individual on the employee.” 11 For that proposition, it relies on Ashburn, 306 Md. at 631, 510 A.2d at 1085.
Specifically, the majority concludes that “neither a dispatcher’s receipt of a call for help nor the dispatch of emergency assistance alone creates a special duty to the person in need of such assistance.” 370 Md. at 498, 805 A.2d at 402-03 (quoting Fried, 139 Md.App. at 260, 775 A.2d at 448). Moreover, it *518asserts that “there is no indication that [the 911 operator’s] handling of Donte W’s call exceeded or was markedly different than her handling of other similar calls and situations.” Id. at 498-99, 805 A.2d at 403. The majority also rejects the argument that the answering and handling of 911 calls are acts for the protection or assistance of a specific group of individuals, i.e., foreseeable plaintiffs. It reasons:
“By its terms, this statutory scheme does not create an emergency system to benefit a discrete group of persons. Rather, in providing for such broad services, it recognizes that, at different times, any and all citizens of, or visitors in, Maryland may find it neeessary to utilize that system for innumerable purposes. In our view, acting to protect or assist a ‘specific group of individuals,’ sufficient to create a special relationship, involves more than general actions taken to serve members of the public at large in need of emergency telephone services. To find otherwise, by equating a duty to act with the provision of a general public service, might jeopardize the availability of those services in the first instance.”
Id. at 498-500, 805 A.2d at 403-04.
Finally, the majority points out that the victim in Fried did not rely on the assistance sought from 911, either directly or actually, having neither been informed of the call or aware of it and, in any event, she was not entitled to the transfer of reliance of the third party in that case because that third party was a perpetrator of the act, thus presenting a scenario that society is unwilling to accept “as reasonable or justifiable.” For these various propositions, it relies on Wanzer v. District of Columbia, 580 A.2d 127, 132 (D.C.App.1990) (“A one-time call to 911 for help is not enough to establish a special relationship.... To give rise to a special relationship, the agency’s response to the private party must in some demonstrable way exceed the response generally made to other members of the public”); Hines v. District of Columbia, 580 A.2d 133, 136 (D.C.1990) (“[T]he mere fact that an individual has emerged from the general public and become an object *519of the special attention of public employees does not create a relationship which imposes a special legal duty”); Morgan v. District of Columbia 468 A.2d 1306, 1313 (D.C.1983) (no special relationship “when the police gratuitously promise to provide protection.... Reassuring a citizen victimized by criminal conduct that help is on the way certainly does not mean that at all costs the action promised inexorably must follow ....”); and Koher v. Dial, 653 N.E.2d 524, 526 (Ind.Ct.App.1995) (“Standing alone, a governmental entity’s dispatch of emergency services does not create a private duty.”).
Ashburn contributes little of real substance to this discussion because it is easily distinguishable. Significantly, it does not involve the 911 emergency system. There, a police officer came upon a man, who was intoxicated and sitting behind the wheel of a pickup truck, whose engine was running and lights were on, on the parking lot of a 7-11 store. Rather than arrest the man for drunk driving, as he could have done, the officer elected instead to tell the man to pull his truck to the side of the lot and to discontinue driving that evening. When the officer left, the man drove the truck away from the lot, proceeded a short distance and collided with a pedestrian, who sued, claiming the officer’s negligence. 306 Md. at 619-20, 510 A.2d at 1079. The analogy would be closer had the officer received a report of a drunk driver in the neighborhood and chosen to do nothing. Another interesting issue would have been presented had the drunk sued the officer.
Turning to the other cases on which the majority relies, Morgan v. District of Columbia 468 A.2d 1306 (D.C.1983), itself, acknowledges its inappositeness to the case sub judiee: “it is important to state first what this case is not about. It is not about a situation where the police do not respond to an urgent call from a citizen who is in immediate danger of being harmed.” Id. at 1310. Neither it, nor any of the others,12 is persuasive, in any event.
*520The reasoning of the cases on which the majority relies, fails completely to take account of the legislative purpose in enacting legislation similar to the Maryland 911 legislation and, thereby, undermines and potentially renders the 911 system meaningless and useless. Indeed, to suggest that the operators of a 911 call system, mandated, financed, governed and directed by the State, has no duty to those who deign to use it, taking the government at its word that it will respond to their emergency timely and appropriately, simply does not make sense. As we have seen, the purpose for establishing the 911 emergency system and requiring the subdivisions to implement it was to create a centralized clearinghouse for such calls, the expectation being that that would enhance efficiency and expedition. Increased efficiency and expedition was not desired simply for their own sake, but for the sake of the lives and the property of Maryland citizens. The General Assembly recognized “the paramount importance of the safety and well-being of the citizens of Maryland” and “that when the lives or property of its citizens are in imminent danger, timely and appropriate assistance must be rendered,” § 18-101(a), and expressed concern “that avoidable delays in reaching appropriate emergency aid are occurring to the jeopardy of life and property.” See § 18-101(c).
An emergency system with the purpose of providing timely and appropriate response to calls reporting emergencies affecting the lives and property of citizens simply has no point if the purpose need not be fulfilled, if those charged with the responsibility of responding owe no duty to those who call or to those for whose benefit the system was established. I can see no reason to have a system with such high ideals as expressed in the legislation if there can be a failure to fulfill the purpose without consequence. The consequence of such a *521scenario is a system with no rational basis and no incentive for those operating it to demand that it live up to, and achieve, its purpose.
In Wanzer, the District of Columbia Court of Appeals tells us that it takes more than one call to 911 for help to establish a special relationship and that a special relationship requires that the agency’s response to the caller in “some demonstrable way exceed the response generally made to other members of the public.” 580 A.2d at 132. It goes on to state: “Even a series of contacts over a period of time between a public agency and an injured or endangered person is not enough to establish a special relationship, absent some showing that the agency assumed a greater duty to that person than the duty owed to the public at large.” Id. This does not make sense. The only reason anyone calls 911 is for help and, in Maryland, at least, that is prompted by the invitation the public is given to use an effective system, along with the promise of a timely and appropriate response. When the system actually is used, it is the existence of the system, the invitation to use it by holding out that there are benefits that flow from it, i.e., the promise of results, timely and appropriate response, from which a duty flows. That is the special relationship; there need be no other. The more pertinent observation to me, therefore, is that the 911 operator did not negate, avoid, the special relationship, by not answering, or better yet, telling the caller what would be the truth if the majority is correct, that he or she did not owe the caller a duty and, consequently, help may, or may not, be forthcoming.
Just as important, if the 911 system is to operate as intended, the response to each call will be generally the same — the caller will report the emergency, respond to whatever reasonable questions are required to allow for the dispatch of assistance and the operator will indicate what the response will be, indicate that help is coming. There neither should or ought to be a response that “demonstrably” exceeds another. After all, only those members of the public needing the emergency assistance will call, thereby triggering the need for a response. If the comparison is to the public at large, as *522it seems to be, then the response to a 911 caller will always be, it is hoped, greater than that to the public at large, to whom the operator simply does not, and has no occasion to, relate.13
The statement in Morgan that reassuring a crime victim that help is on the way does not mean that it must, at all costs, arrive, is true. The difficulty I have is the context. The Court suggests, if not explicitly holds, that the 911 operator’s negligence is an acceptable excuse for the help not arriving. When help does not arrive despite the non negligent action of the 911 operator, that is one thing. It is quite another when the sole reason for help not arriving is the negligence of the 911 operator. The latter is unacceptable, given the statutory scheme and the holding out of the 911 system as being beneficial and efficient in an emergency. I repeat, I believe a special relationship is created when a caller calls 911 to report an emergency, responding to such calls being, in addition to the expressed legislative purpose, the only purpose. It seems *523to me to follow that to avoid a duty to the caller the 911 operator must negate that special relationship by advising the caller that the system does not promise help or equivocate the promise of help.
Hines tells us that a member of the general public can become the object of special attention and yet still not be entitled to a special legal duty. If a member of the general public is not owed a duty and one who has emerged from the general public and become the object of special attention is not owed a duty, perhaps no one is owed a duty. That would be fine if the Legislature had exempted 911 operators from suits for simple negligence arising out of their employment, as it has done with regard to other emergency personnel. See e.g. Md Code (1974, 1998 Replacement Volume) §§ 5-603 of the Courts & Jud. Proc. Article (exempting those who offer emergency medical care at the scene of injury without a fee from liability unless the actions are grossly negligent); § 5-604 (exempting fire and rescue companies from liability unless willful or grossly negligent); § 5-605 (law enforcement officer acting outside jurisdiction).
To be sure, the victim in Fried neither knew nor was informed that someone was calling 911 on her behalf. It is likewise true that she did not have a familial or other close relationship with those who called 911 on her behalf, who were themselves the perpetrators of the acts resulting in the victim being in peril. The majority finds no duty for those reasons. I do not agree. Many victims in need of 911 service will not be able, either physically or because not near a phone to call 911. Those who are incapacitated will not be aware that help has been sought. Some will be discovered by strangers, who nevertheless will seek the help of 911 and a few, as in the present case, may have the perpetrator make the call. Why there would be a duty in one case and not in the others is not at all clear to me. When the victim is foreseeable, it seems to me to be of less consequence how the 911 system became aware of the emergency than what it does, or is required to do, to respond. So what if the victim does not know that help has been summoned or that it is summoned by someone he or *524she does not know or even by someone who is culpable? Focusing on how the system is informed of the emergency misses the point — the emergency exists whoever reports it and whoever knows of the reporting and whoever perpetrates the offense giving rise to the emergency.
In my view, there is a duty owed by the 911 operator and the system to 911 callers and foreseeable plaintiffs when calls are placed to 911, consistent with the system’s holding out of its merits and benefits, and the operators are informed of emergency situations requiring emergency assistance. Accordingly, I would reverse both of the judgments and remand for new trials.14
I dissent.
. Maryland Code (1957, 1997 Replacement Volume, 2001 Cum. Sup.) Article 41, § 18-101(0(5) defines "911 system” as "a telephone service which meets the planning guidelines established pursuant to § 18-103 ..., and which automatically cpnnects a person dialing the digits 911 to an established public safety answering point. 911 system includes equipment for connecting and outswitching 911 calls within a telephone central office, trunking facilities from the central office to a public safety answering point, and equipment to connect 911 calls to the appropriate public safety agency.”
. Hereinafter, unless otherwise indicated, future statutory references will be to this article and chapter.
. An "enhanced 911” system is:
“a 911 system that provides:
"(i)Automatic number identification;
"(ii)Automatic location identification; and
"(iii)After July 1, 1995, other future technological advancements that the Board may require.”
Section 18-101(0(6).
. As the majority points out, the public duty doctrine has been applied to the actions of 911 operators and dispatchers. See, e.g., Sullivan v. City of Sacramento, 190 Cal.App.3d 1070, 235 Cal.Rptr. 844 (1987); Johnson v. District of Columbia, 580 A.2d 140 (D.C.1990); Hines v. District of Columbia, 580 A.2d 133 (D.C.1990); Wanzer v. District of Columbia, 580 A.2d 127 (D.C.1990); City of Rome v. Jordan, 263 Ga. 26, 426 S.E.2d 861 (1993); DeLong v. County of Erie, 60 N.Y.2d 296, 469 N.Y.S.2d 611, 457 N.E.2d 717 (1983); Bratton v. Welp, 145 Wash.2d 572, 39 P.3d 959, 961 (2002).
. The majority reasons, as the Court of Special Appeals explained in Fried v. Archer, 139 Md.App. 229, 257, 775 A.2d 430, 446, cert. granted, 366 Md. 246, 783 A.2d 221 (2001):
'[f]or the courts to proclaim a new and general duty of protection in the law of tort, even to those who may be the particular seekers of protection based on specific hazards, could and would inevitably determine how the limited police resources of the community should be allocated and without predictable limits.’ ” Fried, 139 Md.App. at 258, 775 A.2d at 447 (quoting Riss v. City of New York, 22 N.Y.2d 579, 293 N.Y.S.2d 897, 240 N.E.2d 860, 861 (1968)). By applying the public duty doctrine to 911 personnel, we are able to prevent "that new and general duty of protection” from resulting "in the reduction of public safety services, including emergency response programs and personnel, to the community.” Id. See also Wanzer v. District of Columbia, 580 A.2d 127, 132 (D.C.1990) (“If it were otherwise, then the city would be potentially liable for ‘every oversight, omission, or blunder' of its official-a liability which potentially could so deplete the resources necessary to provide police protection, fire protection, and ambulance service as to result in the elimination of those services altogether.”).’ ”
370 Md. at 490-91, 805 A.2d at 397-98.
. The majority rejects the applicability of the good Samaritan rule in favor of, as we have seen, the public duty doctrine. I do not quarrel with that decision, the approach it adopts being the one followed by other courts that have faced the issue. See note 4, supra. In truth, however, the logic of the distinction that is being drawn between the two approaches escapes me. This Court commented in Ashburn v. Anne Arundel Co., 306 Md. 617, 631, 510 A.2d 1078, 1085 (1986), that "[tjhis 'special duty rule,’ as it has been termed by ihe courts, is nothing more than a modified application of the principle that although generally there is no duty in negligence terms to act for the benefit of any particular person, when one does indeed act for the benefit of another, he must act in a reasonable manner. In order for a special relationship between police officer and victim to be found, it must be shown that the local government or the police officer affirmatively acted to protect the specific victim or a specific group of individuals like the victim, thereby inducing the victim’s specific reliance upon the police protection.”(cifations omitted). The Supreme Court of Minnesota, in Cracraft v. City of St. Louis Park, 279 N.W.2d 801, 806 (1979), made the same point:
" 'Special duty’ is nothing more than convenient terminology, in contradistinction to 'public duty,' for the ancient doctrine that once a *510duty to act for the protection of others is voluntarily assumed, due care must be exercised even though there was no duty to. act in the first instance.... ‘Special duty,’ therefore, could also effectively be termed ‘assumed’ duty.”
(Citation omitted). Restatement (Second) Of Torts § 323 (1965), on which the appellants and the petitioner rely, provides:
" § 323 Negligent Performance of Undertaking to Render Services. One who undertakes, gratuitously or for consideration, to render services to another which he should recognize as necessary for the protection of the other's person or things, is subject to liability to the other for physical harm resulting from his failure to exercise reasonable care to perform his undertaking, if
(a) his failure to exercise such care increases the risk of such harm, or
(b) the harm is suffered because of the other’s reliance upon the undertaking.”
I agree with the majority’s rejection of the the argument made by the appellees and the respondent that 911 operators are public officials entitled to public official immunity.
. In these cases, given the result the majority opinion requires, they were arguably twice victimized, first by the actual perpetrators of the harm and then by the 911 system operators who responded negligently.
. The majority relies on the last portion of the quoted passage, that speaking to the victim’s reliance on the assurances of the 911 operator, *516to support its “reliance as a factor” analysis. What is significant, but the majority fails to acknowledge, is that that portion negated any argument that the issue in that case could be decided as a matter of law.
. But see Laskey v. Martin County Sheriff's Department, 708 So.2d 1013 (Fla.App.1998). In that case, recovery was denied in the plaintiff's action against the sheriff for negligence in failing timely to forward a 911 call, where the plaintiff’s husband was killed in a head-on collision with another vehicle proceeding the wrong way on a limited access interstate highway several minutes after an unidentified 911 caller reported that a vehicle was heading south in a northbound lane of that road. Rejecting the plaintiff’s contention that tire sheriffs office, in operating the 911 service, had a duty to “dispatch” law enforcement personnel in response to the call and breached that duty by not following its own procedures, the court stated, "Any duty to relay calls regarding traffic offenders is a duty owed the public as a whole and not to any third party who may subsequently be injured by the act of the traffic offender.”
. In Lewis v. City of Indianapolis, 554 N.E.2d 13, 17, n. 4 (1990), there was no liability on the part of the City. There, the claim was that the City emergency response was untimely, premised primarily on inability to reach the operator quickly. The court noted, however, that there was nothing to indicate that the victim had any special relationship with the City giving rise to a special, individualized duty on the defendant's part toward him and that the victim's stepdaughter "was not lulled into inaction by the 911 operator, whom she never reached. Moreover, when Vanessa’s grandmother reached a 911 operator, assistance was immediately dispatched to the correct address.”
. While acknowledging that the Court of Special Appeals' use of "specific reliance” under the public duty test to mean “detrimental and justifiable reliance,” consistent with the holdings of courts in other jurisdictions, Fried, 139 Md.App. at 265-66, 775 A.2d at 451, the majority did not adopt that definition, choosing instead, "to retain a more general special relationship test to preserve our case-by-case analytical approach to these issues” and to note "that those principles, along with others, may provide useful tools for assessing the reliance, actual or transferred, in a particular case.” 370 Md. at 496, n. 31, 805 A.2d at 401, n. 31.
. Koher v. Dial, must be read in the context of legislative action, the passage of subsection (18) of Ind.Code § 34-4-16.5-3, granting a governmental entity immunity under the Tort Claims Act for the operation *520of "an enhanced emergency communication [or ’911’] system.” Benton v. City of Oakland City, 721 N.E.2d 224 (Ind.1999). See Barnes v. Antich, 700 N.E.2d 262, 266 n. 6 (Ind.Ct.App.1998) ("a plain reading of Ind.Code 34-4-16.5-3(18) leads inescapably to the conclusion that the legislature intended to afford immunity from claims arising out of a municipality's operation and use of [a '911' service]”).
. In Hines v. District of Columbia, 580 A.2d 133, 138 (D.C.1990), the court opines:
"Appellant argues that the regulations, Mayor's order, and protocols applicable to the District’s Emergency Ambulance Division create such a class of individuals — ‘persons who are seriously ill or injured and who receive emergency medical care and transportation by the Emergency Ambulance Division.’ Appellant supports this argument by analogy to the source of the duty in Turner[ v. District of Columbia, 532 A.2d 662 (D.C.1987)], that is, the Child Abuse Prevention Act, D.C.Code § § 6-2101-2127 (1989 Repl.). We find the analogy unpersuasive. Virtually every citizen of the District could find himself or herself in need of assistance from the EAD at one time or another; if there is a particular 'class’ of citizens who benefit, its members are distinguished from the general public only in that they are temporarily in need of emergency services. In this, they do not differ from citizens who find themselves in need of emergency police or fire services. See Wanzer v. District of Columbia, supra, 580 A.2d at 132-133. All of us may be temporary members of one or more of these 'classes' at some time. There exists no 'class’ in the sense that would justify invoking the special relationship exception to the public duty . doctrine.”
If I understand the court, it is saying that if one is a potential member of a class, even one that is reasonably differentiated from other members of the public, there can be no special relationship. The majority engages in a similar discussion, using similar "logic.” The logic, I confess, escapes me.
. The majority does not address the special relationship test in Muthukumarana, concluding that the circumstances demonstrate that the 911 operator in that case, was not negligent. I do not agree. In my opinion, whether the 911 operator was negligent is a jury question. To be sure, the majority's conclusion is a permissible one for a trier of fact to draw after considering all of the evidence; however, I am far from satisfied that all of the inferences drawn from the 911 recorded call require that conclusion. In fact, I believe a jury could well decide on the basis of the recording itself, viewed in light of the circumstances and in the light most favorable to the plaintiff, that the 911 operator was negligent.