In Semple v. Tri-City Drywall, Inc., 172 Ariz. 608, 838 P.2d 1369 (App. 1992), a panel of this court held that a proceeding before the ROC is not an "action" and the prevailing party is therefore not entitled to an award of its attorneys' fees under 12-341.01(A). Id. at 611, 838 P.2d at 1372. In reaching this conclusion, the court found that an "action" is "a proceeding before a court of law," and it reasoned that, because an administrative agency is not a "court of law," a proceeding before the ROC is not an "action" under 12-341.01(A). Id. Accordingly, it found the superior court erred by awarding Tri-City its attorneys' fees under 12-341.01(A) as the prevailing party before the ROC. Id. at 612, 838 P.2d at 1373.