California, United States of America
The following excerpt is from Nightingale v. Hyundai Motor America, 29 Cal.App.4th 1332, 35 Cal.Rptr.2d 132 (Cal. App. 1994):
4 Attorney fees may be incurred by a buyer even though the fees have not been paid. The question is whether the buyer has incurred an obligation to pay the fees. " '[I]ncurred' means 'to become liable for' as distinguished from actually 'pay for.' " (Board of Education v. Commission on Professional Competence (1980) 102 Cal.App.3d 555, 563, 162 Cal.Rptr. 590.)
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