This determination is in harmony with multiple other courts that have contemplated this very issue. Such courts have repeatedly held that billing and/or fee-setting practices do not constitute “professional services.” See Gregg, 316 F.Supp.2d at 513 (citing Atlantic Lloyd’s, 982 S.W.2d at 476-77) (reasoning that “even tasks performed by lawyers are not considered ‘professional services’ if they are ordinary activities that can be completed by those lacking legal knowledge and skill.”); see Med. Records Assocs., Inc. v. Am. Empire Surplus Lines Ins. Co., 142 F.3d 512 (1st Cir.1998) (“Indeed, setting a price for services and sending bills are functions of every-business.”); Visiting Nurse Ass’n of Greater Phil. v. St. Paul Fire & Marine Ins. Co., 65 F.3d 1097, 1101 (3rd Cir.1995) (<HOLDING>). In Reliance Nat. Ins. Co. v. Sears, Roebuck &
holding that a professional owes no duty to third persons unless the professional had actual knowledge that those persons would rely on his rendering of professional services recognizing a traditional distinction between the public and governmental acts of sovereign states on the one hand and their private and commercial acts on the other holding in case where the asserted defense to plaintiffs contract action to recover fees for his professional services was that the professional services were for the unlicensed practice of law in new jersey and that the contract was therefore illegal and unenforceable that questions of unlawful practice of law will turn on the particular facts presented that the issue could be determined only on a full and complete appreciation of the events and surrounding circumstances that the trial court not evaluate the merits of appellees affirmative defense without reference to matters outside the pleadings and therefore that judgment on the pleadings was not warranted holding that negligence on the part of a legal secretary is imputed to the supervising attorney and the statute of limitations for professional services applies to both recognizing the division between the professional and commercial aspects of the practice of law the third circuit reasoned the professional aspect involves the rendering of legal advice to and advocacy on behalf of clients for which the attorney is held to a certain minimum professional and ethical standard  on the other hand the commercial aspect involves the setting up and running of a business including such tasks as securing office space hiring staff paying bills and collecting on accounts receivable