Advanced Micro Devices, Inc. v. Intel Corp. (1994) 9 Cal.4th 362, set forth the standard by which courts are to determine whether a contractual arbitrator has exceeded his or her powers in awarding relief for breach of contract. Under this standard, in the absence of more specific restrictions in the arbitration agreement, "the remedy an arbitrator fashions does not exceed his or her powers if it bears a rational relationship to the underlying contract, as interpreted, expressly or impliedly, by the arbitrator." (Id. at pp. 367, 381.) The arbitrator's award "will be upheld so long as it was even arguably based on the contract; it may be vacated only if the reviewing court is compelled to infer the award was based on an extrinsic source." (Id. at p. 381.) A manufacturer entered into an agreement with another party regarding the rights to a computer chip. The agreement contained a clause requiring the arbitration of disputes. (Id. at pp. 368-369.) After the parties fell into a dispute, an arbitrator found that the manufacturer had breached the agreement, and as a remedy, the arbitrator awarded control over the chip to the other party. (Id. at pp. 369-370.) The trial court confirmed the award. (Id. at p. 371.) On appeal, the manufacturer contended that the remedy effectively re-wrote the underlying agreement. (Advanced Micro Devices, supra, 9 Cal.4th at p. 372.) In addressing this issue, our Supreme Court affirmed that courts generally defer to arbitrators' assessments of their contractual authority, and that arbitrators may base their decisions on principles of justice and equity unless expressly required to follow legal rules. (Id. at pp. 372-375.) Given these principles, the court in Advanced Micro Devices concluded that "arbitrators, unless expressly restricted by the agreement of the parties, enjoy the authority to fashion relief they consider fair and just under the circumstances existing at the time of arbitration, so long as the remedy may be rationally derived from the contract and the breach." (Id. at p. 383.) The court further remarked that parties to commercial contracts who wish to restrict the arbitrator's remedial authority "would be well advised to set out such limitations explicitly and unambiguously in the arbitration clause," reasoning that "arbitrators may not award remedies expressly forbidden by the arbitration agreement or submission . . . ." (Id. at pp. 381, 383.) Applying these conclusions to the case before it, the Advanced Micro Devices court determined that the remedy at issue was rationally related to the underlying contract and its breach. (Id. at p. 385.) In Advanced Micro Devices, Inc. v. Intel Corp. (1994) 9 Cal. 4th 362, the Supreme Court held an arbitration award must be upheld unless the relief granted bears no rational relationship to the arbitration contract. "The award will be upheld so long as it was even arguably based on the contract; it may be vacated only if the reviewing court is compelled to infer the award was based on an extrinsic source." ( Id. at p. 381, .) In Advanced Micro Devices, the arbitrator fashioned an equitable remedy for defendant's breach of contract based on his interpretation of the parties' contracts and in light of the testimony provided during a lengthy hearing. ( Id. at pp. 369-371.) The trial court confirmed the award, but the Court of Appeal reversed, finding the arbitrator had exceeded his authority by creating a remedy with no " 'rational nexus' " to the parties' underlying contract. ( Id. at p. 371.) The Supreme Court reversed, holding courts may not review de novo the remedies fashioned in arbitration, due to the need for and expectation of finality and the nature of arbitration proceedings. "A reviewing court is thus not in a favorable position to substitute its judgment for that of the arbitrators as to what relief is most just and equitable under all the circumstances." ( Id. at p. 375.) The California Supreme Court "decided the standard by which courts are to determine whether a contractual arbitrator has exceeded his or her powers in awarding relief for a breach of contract." (Id. at p. 366.) The court concluded that, "in the absence of more specific restrictions in the arbitration agreement, the submission or the rules of arbitration, the remedy an arbitrator fashions does not exceed his or her powers if it bears a rational relationship to the underlying contract as interpreted, expressly or impliedly, by the arbitrator and to the breach of contract found, expressly or impliedly, by the arbitrator." (Id. at p. 367.) "Fashioning remedies for a breach of contract or other injury is not always a simple matter of applying contractually specified relief to an easily measured injury. . . . It may require . . . finding a way of approximating the impact of a breach that cannot with any certainty be reduced to monetary terms. Passage of time and changed circumstances may have rendered any remedies suggested by the contract insufficient or excessive." (Advanced Micro, supra, 9 Cal.4th at p. 374.) "The choice of remedy, then, may at times call on any decisionmaker's flexibility, creativity and sense of fairness. In private arbitrations, the parties have bargained for the relatively free exercise of those faculties. Arbitrators, unless specifically restricted by the agreement to following legal rules ' "may base their decision upon broad principles of justice and equity . . . ." As early as 1852, this court recognized that, "The arbitrators are not bound to award on principles of dry law, but may decide on principles of equity and good conscience, and make their award ex aequo et bono according to what is just and good." Were courts to reevaluate independently the merits of a particular remedy, the parties' contractual expectation of a decision according to the arbitrators' best judgment would be defeated." (Id. at pp. 374-375.) Moreover, "independent reevaluation by a court . . . is unlikely to be either expeditious or accurate." (Id. at p. 375.) An arbitrator's exercise of discretion is not unlimited. Courts still "retain the ultimate authority to overturn awards as beyond the arbitrator's powers, whether for an unauthorized remedy or decision on an unsubmitted issue." (Advanced Micro, supra, 9 Cal.4th at p. 375.) But the standard of review is narrow and deferential. (Id. at p. 376.) Moreover, the review must accept the factual and legal determinations made by the arbitrator. (Ibid.) In sum, the remedy awarded must bear "some rational relationship to the contract and the breach." (Advanced Micro, supra, 9 Cal.4th at p. 381.) An award is rationally related to the breach "if it is aimed at compensating for, or alleviating the effects of, the breach." (Id. at p. 381, fn. 12.) The required link "may be to the contractual terms as actually interpreted by the arbitrator . . . , to an interpretation implied in the award itself, or to a plausible theory of the contract's general subject matter, framework or intent." (Id. at p. 381.) While it is true that the arbitrator may not award a remedy expressly forbidden by the contract, there is no requirement that the remedy exactly correspond to the rights and obligations had the contract been performed. (Id. at pp. 381-382.) If the parties wish the arbitrator's remedial authority to be restricted, they "would be well advised to set out such limitations explicitly and unambiguously in the arbitration clause. (Id. at p. 383.) In Advanced Micro Devices, Inc. v. Intel Corp. (1994) 9 Cal.4th 362, the trial court confirmed an award in an arbitration between two microchip manufacturers awarding a very broad remedy, but the Court of Appeal reversed, finding itself "unable to locate a 'rational nexus' between paragraphs ... of the award and the contract itself. Therefore, the court concluded, the arbitrator had improperly 'rewritten the parties' agreement'" in paragraphs that could not be treated as surplusage without affecting the merits of the decision. (Id. at p. 371.) The Supreme Court reversed the Court of Appeal, acknowledging that "arbitrators may not award remedies expressly forbidden by the arbitration agreement or submission ... ." (Id. at p. 381.) "The remedy awarded, however, must bear some rational relationship to the contract and the breach. The required link may be to the contractual terms as actually interpreted by the arbitrator (if the arbitrator has made that interpretation known), to an interpretation implied in the award itself, or to a plausible theory of the contract's general subject matter, framework or intent. The award must be related in a rational manner to the breach (as expressly or impliedly found by the arbitrator)." (Id. at p. 381.) The Supreme Court found it "difficult to see" "how the violation of ' "an express and explicit restriction on the arbitrator's power" ' could be considered rationally related to a plausible interpretation of the agreement ... ." (Id. at pp. 381-382.) The Court held: "An exception to the general rule assigning broad powers to the arbitrators arises when the parties have, in either the contract or an agreed submission to arbitration, explicitly and unambiguously limited those powers. (Advanced Micro Devices, supra, 9 Cal.4th at pp. 375-376, 383.) "The scope of an arbitrator's authority is not so broad as to include an award of remedies 'expressly forbidden by the arbitration agreement or submission.'" (Advanced Micro Devices, at p. 381.) "Arbitrators are not obliged to read contracts literally, and an award may not be vacated merely because the court is unable to find the relief granted was authorized by a specific term of the contract." (Advanced Micro Devices, at p. 381.)