San Luis Obispo Bay Properties, Inc. v. Pacific Gas & Elec. Co. (1972) 28 Cal.App.3d 556, suggests that the parties can effectively limit the forms of actions to which attorney's fees are applicable, and that reciprocity would only extend to those few actions provided. In San Luis, the original subleasing contract contained a unilateral attorney's fee provision applicable to suits for unlawful detainer or "any other covenant herein contained." ( Id. at p. 570.) The action in the trial court was brought to vacate an arbitration award made as provided in a modification of the original contract. The court sustained the award of attorney's fees because it observed that "paragraph 22 of the sublease does not limit the right to recover attorney fees to those incurred in any particular form of lawsuit." ( Id. at p. 571.)