Defendant’s $200,000 998 offer was clear, not ambiguous, and was enforceable when plaintiff recovered less than $200,000–even though the offer did not refer to the workers’ compensation lien and state whether settlement proceeds could be used to recoup the lien. Absence of a reference to the workers’ comp. lien didn’t render the offer uncertain or invalid. A party making a section 998 offer “need not take into account a lien against the judgment when making the offer.” (Manthey v. San Luis Rey Downs Enterprises, Inc. (1993) 16 Cal.App.4th 782, 791; Culbertson v. R. D. Werner Co., Inc. (1987) 190 Cal.App.3d 704, 708.)