In Boyd v. Oscar Fisher Co., Inc. (1989) 210 Cal. App. 3d 368, there was a written dealership agreement between the manufacturer of photographic equipment and its dealer. After the original agreement had been executed, the manufacturer sent the dealer invoices for goods, and those invoices contained an attorney fees provision. Many of the same arguments made by Dynamic in the case at bench were made and rejected in Boyd, which held that the invoices in that case were part of the contract although sent after the dealership agreement had been signed. (210 Cal. App. 3d 368, 379.) However, the dealer in Boyd had been employed by the manufacturer, going from sales to management, before leaving New York for California to act as a dealer. He asked the manufacturer to be billed by manufacturer rather than collecting his commission after the manufacturer was paid. ( Id. at p. 374). Moreover, the dealer was aware that the manufacturer's standard invoice provided: "If referral to a collection agency or an attorney becomes necessary as a result of non-payments cost of collection proceedings including reasonable attorneys fees shall be added to the amount due." (Ibid.) The dispute between the parties in Boyd began when dealer began selling a competing product and manufacturer therefore terminated dealer's exclusive dealership. ( Id. at p. 375) Dealer sued manufacturer; manufacturer filed a cross complaint and filed a motion for attorney fees, which was granted and upheld on appeal. ( Id. at pp. 376-380.) The Boyd court found that substantial evidence "supports implicit conclusions that the parties were merchants who added terms to the dealership agreement by subsequent invoices," including the attorney fees agreement. ( Id. at p. 379.)