In Boyd v. Oscar Fisher Company, Inc. (1989) 210 Cal. App. 3d 368, the Court explained the effect of section 1717(a) in contract actions containing limited attorney fees provisions. In that case a dealer brought an action alleging that the manufacturer had wrongfully terminated an exclusive dealership agreement. The manufacturer cross-complained for collection of unpaid invoices. The dealership agreement did not contain an attorney's fees provision but the invoices provided for fees in any action for collection. There was no incorporation provision. The manufacturer prevailed on both actions, and the dealer sought to limit attorney's fees only to the cross-action for collection. The court first found that the invoices should be deemed incorporated into the dealership agreement as subsequently added terms. It then rejected the dealer's argument that the attorney's fees provision should apply only to the action to collect on the invoices.