In Lozada v. City and County of San Francisco (2006) 145 Cal.App.4th 1139, the appellate court held: "We are not persuaded that substantial civil penalties and actual damages do not constitute 'money or damages' within the meaning of the Government Claims Act. While there appears to be a split of authority over whether money damages that may be 'incidental' to a claim for equitable relief are subject to the claim filing requirement of the Government Claims Act, we are aware of no case that holds that civil penalties of the type sought here ($25,000 per incident) and actual damages that are the primary relief sought and not merely 'incidental' to injunctive or other extraordinary relief, do not constitute a claim for 'money or damages' in the first instance."