In Chamberlin v. Dale's R.V. Rentals, Inc. (1986) 188 Cal.App.3d 356, the Court construed section 917.1 and held that in determining the amount of an undertaking, the trial court must consider the amount of a Civil Code section 1717, subdivision (a) attorney fee award. The Bank of San Pedro v. Superior Court (1992) court described Chamberlin's holding: "Because the case was decided before the 1986 amendment to section 917.1 (which requires the inclusion of costs in a damages judgment when computing the amount of the undertaking), the question was whether the award of attorney fees under Civil Code section 1717 had to be included within the judgment in computing the amount of the undertaking. The court concluded the then-existing rule that costs were not included for such purpose did not extend to the award of attorney fees. 'Unlike the costs involved in the early cases, such attorney fees are in the nature of a directly litigated issue rather than merely incidental to the judgment. Further, attorney fees are not the type of costs involved in virtually every case. Attorney fees are awarded only in limited situations.' " (Bank of San Pedro, supra, 3 Cal.4th at p. 802, quoting Chamberlin, at p. 362.) In Nielsen v. Stumbos (1990), the Third District Court of Appeal distinguished Chamberlin to hold that "the language of Civil Code section 1717 and recent legislation affecting related statutes leads us to conclude that contractual attorney fees awarded a party who recovers no money damages are to be treated as any other incidental cost of litigation for purposes of the automatic stay provisions of ... section 916. Accordingly, no undertaking need be posted by the plaintiff, the appellant here." The Nielsen court observed that Chamberlin involved a judgment for not only attorney fees, but also money damages. (Nielsen, at p. 305.) Nielsen held the automatic stay applied when there was no money judgment, only an award of attorney fees and costs. (Ibid.)