Can a defendant waive a challenge to a trial court's failure to instruct on a lesser included offense?

^13. A defendant may nevertheless waive a challenge to the trial court's failure to instruct on a lesser included offense under the doctrine of invited error. (See People v. Souza (2012) 54 Cal.4th 90, 114 [claim may be waived if counsel intentionally causes trial court to err and "expresses a deliberate tactical purpose" in doing so].) We need not decide whether this doctrine applies here, as the Attorney General does not invoke it, and because, as discussed below, we conclude the failure to instruct on any lesser included offense was not prejudicial.