Defendant’s 998 offer was valid and shifted costs when plaintiff later settled for the same amount as the 998 offer.  The offer was to pay Chen $160,000; he would be required to return the car with clean title; and he would be allowed to seek an award of attorney fees and costs by noticed motion, the amount to be determined by the court. The offer was easy to understand.  It was not made ambiguous by silence about who was the prevailing party or whether the car would be deemed a Lemon Law Buyback.  Similarly, the failure to mention “expenses” recoverable under the Song-Beverly Act didn’t render the offer invalid.  An offer silent on costs, expenses or fees allows recovery of those items in addition to the offered sum.