Does the phrase "protect the lien" apply to a tort cause of action?

Moreover, the phrase "protect the lien" is not limited to contract claims or contractual challenges to the terms of the deed of trust. (Cf. Khan v. Shim (2016) 7 Cal.App.5th 49, 60 [attorneys' fees provision applying to "'"an action or proceeding to enforce the terms hereof or declare rights hereunder'"" or "if '"legal action or arbitration is necessary to enforce the terms of this Agreement""' did not apply to tort causes of action].) Rather, the attorneys' fees provision in the deed of trust securing the second loan authorizes an award of attorneys' fees in "any lawsuit or proceeding" the beneficiary "defends to protect the lien." The Arefis' lawsuit was such an action. The trial court did not err in awarding attorneys' fees to Miracle Day.

Page 40