In King v. Larsen Realty, Inc. (1981) 121 Cal. App. 3d 349, the defendants, several realtors, objected to arbitration of a dispute with another realtor regarding a real estate commission on the ground that they had never agreed to arbitration of such disputes. ( King v. Larsen Realty, Inc., supra, 121 Cal. App. 3d at p. 352.) When the defendants had applied for membership in the local board of realtors, however, they had signed an application in which they agreed "'to abide by the Code of Ethics of the National Association of Realtors, and the Constitution, Bylaws and Rules and Regulations" of certain organizations.'" ( Id. at p. 353.) The bylaws of one of those organizations required applicants to agree to arbitrate as set forth in a particular arbitration manual. (Ibid.) The appellate court found that the defendants had contracted to abide by the bylaws, and that the bylaws imposed a duty to arbitrate as set forth in the arbitration manual, which was incorporated into the bylaws by reference. ( Id. at p. 357.)