Atkinson Corp. v. Lumbermen's Cas. Co., 236 Ore. 405, 389 P.2d 32 (1964) involved multiple actions arising out of multiple incidents of paint damage to vehicles. The damages allegedly occurred during the painting of a bridge over a several month period. The cars crossing a nearby bridge were damaged by the paint spray. The defendant was the insurer of all of the damaged vehicles. The court held that each claim of damage, if under the statutory limit, could support a claim for attorney fees under ORS 20.080, whether pled as a separate actions or pled as separate counts in a single action. Atkinson, 236 Ore. at 412.