Ajida Technologies, Inc. v. Roos Instruments, Inc. (2001) 87 Cal.App.4th 534, involved an appeal from a judgment confirming an arbitration award. (Id. at p. 537.) As pertinent to this appeal, the appellate court held that "a contract provision that permits the recovery of fees in arbitration is broad enough to include fees in related judicial proceedings, including an appeal from the judgment confirming the arbitrator's award." (Id. at p. 552.) The Court held that "a party's contractual duty to arbitrate disputes may survive termination of the agreement giving rise to that duty." The question was one of first impression, and one of the sources of guidance cited by the court was the statutory scheme recognizing that written agreements to arbitrate may be extended or renewed by oral or implied agreement. (Ibid.) The court upheld an arbitral award, concluding the arbitrators did not exceed their authority in extending the arbitration and fee provisions from the parties' terminated contract to future controversies. (87 Cal.App.4th at p. 537.) The court concluded the challenged provisions on future dispute resolution were "rationally drawn from the parties' agreement as interpreted in the arbitration proceeding," and "it is not irrational to extend its operation to controversies arising from the very award that interprets the agreement." ( Id. at p. 544.) The court did "expressly hold that a party's contractual duty to arbitrate disputes may survive termination of the agreement giving rise to that duty." (Id. at p. 545.) However, the Court of Appeal was careful to limit its holding to the factual framework presented therein. (Id. at p. 546, fn. 8.) After all, in that case, the parties' underlying agreement "expressly contemplated a continuous relationship for five years after contract termination." (Ibid.)