Duty to 'Perform' Improvements Includes Duty to Pay for Them

What Happened: The following clause, which refers to California Title 24 requiring buildings to meet specific energy efficiency standards, was at the center of a dispute between a landlord and its optical components manufacturing tenant:

Landlord shall be responsible to perform all work to the Premises and/or Building necessary to comply with Title 24 which may be required as a result of the Landlord's Work or Tenant's Work.

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