In Vasquez v. State of California (2008) 45 Cal.4th 243, the court indicated that Graham v. DaimlerChrysler Corp. (2004) adopted a "prelitigation demand requirement" "to guide the exercise of judicial discretion." (Vasquez, supra, 45 Cal.4th at pp. 254-255.) Be that as it may, the catalyst theory was created and has been refined by the judiciary based on various policies, such as rewarding efforts designed to benefit the public. Another policy, equally important to the catalyst theory, was articulated by Graham when it stated: "Awarding attorney fees for litigation when those rights could have been vindicated by reasonable efforts short of litigation does not advance that objective and encourages lawsuits that are more opportunistic than authentically for the public good." (Graham, supra, 34 Cal.4th at p. 577.) As amplified by Vasquez, Graham created the prelitigation demand requirement because "the catalyst theory entails risks and benefits that, on balance, justify the adoption of 'sensible limitations on the catalyst theory that discourage extortionate suits without putting a damper on lawsuits that genuinely provide a public benefit' citation." (Vasquez, supra, 45 Cal.4th at p. 255.)