OPINION
ANDELL, Justice.This is an appeal of a summary judgment granted in favor of the appellee, Griggs & Harrison, P.C. (G & H). We affirm the judgment.
Background
G & H, a professional corporation of attorneys, sued its former client, Judwin Properties, Inc., and Judwin’s insurer, Reliance Insurance Company, for unpaid legal fees. G & H included fee statements in its petition. Judwin counterclaimed against G & H for *869damages sustained as a result of the unauthorized public disclosure of the confidential information contained in the fee statements. G & H settled with Reliance and dismissed its claims against Reliance and Judwin. As a result, only Judwin’s counterclaim remained pending.
G & H moved for summary judgment on the counterclaim, on the basis that it had conclusively negated the element of damages in Judwin’s cause of action. Judwin amended its counterclaim to allege breach of contract, breach of implied warranty, breach of fiduciary duty, negligence, and gross negligence. The trial court concluded G & H was entitled to summary judgment on all of Jud-win’s causes of action.
Judwin appealed. This Court affirmed the summary judgment for the breach of contract, breach of implied warranty, and breach of fiduciary duty claims, but reversed the judgment for the negligence and gross negligence claims and remanded the cause to the trial court to address those issues. Judwin Properties, Inc. v. Griggs and Harrison, 911 S.W.2d 498, 498 (Tex.App.—Houston [1st Dist.] 1995, no writ).
On remand, G & H again moved for summary judgment on the negligence and gross negligence claims. The court rendered summary judgment for G & H; the judgment did not specify grounds on which the court relied. In five points of error, Judwin attacks each of G & H’s bases for summary judgment.
Summary Judgment Review
Judwin’s negligence and gross negligence claims alleged G & H’s disclosure of confidential information violated the duty of ordinary care and diligence exercised by other attorneys in Harris County in the same or similar circumstances and caused Judwin damages.
Negligence requires proof of four well-known elements: (1) the existence of a duty; (2) the breach of that duty; (3) that the breach was a proximate cause of damages; and (4) that the plaintiff was damaged. See Cosgrove v. Grimes, 774 S.W.2d 662, 665 (Tex.1989).
As summary judgment movant, G & H had the burden of showing there was no genuine issue of material fact as to one or more of the essential elements of Judwin’s causes of action, and that it was entitled to judgment as a matter of law. See Nixon v. Mr. Property Management Co., 690 S.W.2d 546, 548 (Tex.1985). In deciding whether there was a disputed material fact issue precluding summary judgment, we will accept evidence favorable to Judwin as true, and we will indulge every reasonable inference and resolve any doubts in Judwin’s favor. See Id. at 548-49. However, because the court’s order does not specify the grounds relied on for its ruling, we will affirm the summary judgment if any of the theories G & H advanced is meritorious. See State Farm Fire & Cas. Co. v. S.S., 858 S.W.2d 374, 378 (Tex.1993).
Evidence Rule 503(d)(3) and Disciplinary Rule 1.05
We address point of error three first because it disposes of the appeal.
G & H sought summary judgment on several bases. One basis was that Rule 503(d)(3) of the Texas Rules of Evidence does not provide an attorney-client confidentiality privilege for matters relevant to a chent’s non-payment of agreed fees. Another basis was that Texas Disciplinary Rules of Professional Conduct (State Bar Rules), Rule 1.05, allowed disclosure.
In point of error three, Judwin argues we should reverse the summary judgment because Texas Rule of Evidence 503(d)(3) and “Texas Rule of Disciplinary Procedure 1.05” do not permit an attorney to damage his client unnecessarily.1 Judwin relies on the following language in comment 15 to State Bar Rule 1.05: “A lawyer entitled to a fee *870must be permitted to prove the services rendered in an action to collect it- Any disclosure by the lawyer, however, should be as protective of the client’s interest as possible.” Tex. DISCIPLINARY R. Prof’l Conduct 1.05 emt. 15, reprinted in Tex. Gov’t Code Ann., tit. 2, subtit. G app. A (Vernon Supp. 1998) (Tex. State Bar R, Art. X, § 9) (emphasis added). Judwin argues that any right to disclose information under Rule 503(d)(3) is subject to the same duty to do so cautiously. Accordingly, Judwin argues, G & H’s reliance on Rule 503(d)(3) did not conclusively negate the negligence claim.
The preamble to the State Bar Rules states: ‘Violation of the Texas Disciplinary Rules of Professional Conduct does not give rise to a private cause of action nor does it create any presumption that a legal duty to a ehent has been breached.... Accordingly, nothing in the rules should be deemed to augment any substantive legal duty of lawyers or the extra-disciplinary consequences of violating such a duty.” Tex. Disciplinary R. Prof’l Conduct 1.05 preamble ¶ 15. Thus, the State Bar Rules were not enforceable through Judwin’s negligence claim.
Rule 503(d) expressly provides: “There is no privilege under this rule: .... [a]s to a communication relevant to an issue of breach of duty by the lawyer to his client or by the client to his lawyer.” Tex.R. Evid. 503(d). Rule 503(d) does not contain any limiting language similar to that in comment 15 to Rule 1.05. Because the legislature could have easily imposed limits on the exception by adding language similar to that in comment 15 to State Bar Rule 1.05, but did not do so, we refrain from implying such a limitation. What remains, then, is a question of whether the plain language of Rule 503(d)(3) was a sufficient basis for summary judgment.
Judwin did not dispute that the fee statements were related to the issue of nonpayment. Rule 503(d)(3) says the attorney-client privilege does not apply to evidence related to a breach issue between the lawyer and client. The lack of privilege favors the finding that G & H had no duty to withhold the information. Tex.R. Evid. 503(d)(3). Accordingly, by citing Rule 503(d)(3), G & H conclusively disproved the duty element of Judwin’s claim and was entitled to summary judgment.
We overrule point of error three and affirm the judgment. Having done so, we need not address Judwin’s other points of error.
O’CONNOR, J., dissents.
. Judwin’s brief misidentifies G & H’s authority as "Texas Rule of Disciplinary Procedure 1.05.” G & H actually relied on Texas Disciplinary Rules of Professional Conduct (State Bar Rules), Rule 1.05. Because Judwin's argument, in substance, attacks G & H’s reliance on the Texas Disciplinary Rules of Professional Conduct, Rule 1.05, we will address the point of error as though Judwin had correctly identified the authority upon which G & H relied.