Is a promissory note that obligates a defendant to pay all costs of collection enforceable?

In Jackson v. Oppenheim, 533 F.2d 826 (2d Cir.1976), plaintiff lost on his underlying securities claim, but defendant was not awarded attorneys' fees merely because the plaintiff signed a promissory note in which he agreed to pay " 'all costs of collection, including, but not limited to, counsel fees....' " Id. at 830. We acknowledged that under New York law a covenant in a note providing for the collection of attorneys' fees expended in "collection" of the note is enforceable. Id. at 831. Yet in order to put a plaintiff on notice that he is undertaking to indemnify a defendant for its costs in defending a separate federal securities laws claim, a covenant must be most specific. Thus, we held that defendant, as seller of the stock, was entitled to recover only attorneys' fees he expended in collecting on the promissory notes given by the buyer-plaintiff. Defendant was not entitled to recover costs for defending against the buyer's security action.