In Frost v. Witter (1901) 132 Cal. 421, the Supreme Court explained: "The latter term action is very commonly confounded with the suit (litis) in which the action is enforced. But this is not the technical meaning of the term, according to which an action is simply the right or power to enforce an obligation. 'An action is nothing else than the right or power of prosecuting in a judicial proceeding what is owed to one,' -- which is but to say, an obligation. (Actio nihil aliud est quam jus persequendi in judicio quod sibi debitur.) The action therefore springs from the obligation, and hence the 'cause of action' is simply the obligation."