In Meininger v. Larwin-Northern California, Inc. (1976) 63 Cal.App.3d 82, section 1717 was held not to be applicable in a case in which the contract provided for attorney's fees in the event of tort claims by third parties. The court held that those claims would be interpreted as not being "actions on the contract" so as to require reciprocation when the parties sue on the contract. ( Id. at p. 85.)