How has the statute of limitations been interpreted in the context of an accounting claim?

The foregoing principles have been applied in cases very similar to this. In Bell v. Bank of California, supra, 153 Cal. 234, 94 P. 889, an action was brought against a pledgee for improperly selling shares of stock. It was filed within four years, but more than three years, after the cause of action arose. An accounting was demanded. The court held that the action was barred by Code of Civil Procedure, 338, subdivision 3. The opinion states, 'It makes no difference that the plaintiff seeks an accounting to determine the value of the stock so transferred. In so far as this may be regarded as an action to recover the value of such property, the gist of the action is the wrongful conversion. The accounting, if it be a proper case for an accounting at all, is merely incidental to the main purpose of the action. The nature of the right sued upon, and not the form of the action nor the relief demanded, determines the applicability of the statute of limitations under our code. * * * It is argued that the complaint should be sustained as a bill in equity for an accounting of all of the transactions of the bank with reference to the security, but the accounting sought, if a case for an accounting is made, would be only incidental to the main relief sought, which is either a redemption of the property sold, or a recovery of its value. Where there can be no relief upon the main ground, the bill will not be retained for the mere purpose of having an accounting which can lead to no useful purpose.' 153 Cal. at pages 242-244, 94 P. at pages 893, 894.