In Jones v. Dumrichob (1998) 63 Cal. App. 4th 1258, a plaintiff who refused a Code of Civil Procedure section 998 offer contended that the trial court abused its discretion in awarding the prevailing defendant discretionary costs. The plaintiff claimed the Code of Civil Procedure section 998 offer to compromise, of a waiver of costs only, "was not a reasonable offer, but rather a token, tactical one made only to preserve the right to later claim these disputed costs." ( Jones, supra, 63 Cal. App. 4th at p. 1262.) However, the Court of Appeal rejected this argument, finding that the plaintiff did not show any factual basis to claim the offer was " 'unrealistic and unreasonable' " or made solely in order to " 'gain a strategic advantage.' " ( Jones, supra, 63 Cal. App. 4th at p. 1263.) Instead, the offer of a waiver of costs was deemed to have a significant monetary value: "Appellants overlook the fact that in offering to have judgment entered against him, respondent defendant was also waiving his considerable cost bill against which appellants' likelihood of success in the case must have been weighed." ( Jones, supra, 63 Cal. App. 4th at p. 1263.)