What is the test for a cause of action for breach of the implied covenant in a non-binding agreement?

agreement. Plaintiff never explicitly alleges this was also a breach of the implied covenant. But reading the complaint liberally, as we must do for our review (Sanchez v. City of Modesto (2006) 145 Cal.App.4th 660, 671), we conclude plaintiff intended to allege breach of the express term of the agreement was also a breach of the implied covenant. Because plaintiff did not sufficiently plead breach of any express covenant, the cause of action for breach of the implied covenant also fails. And for the same reasons as above, there is no basis to grant leave to amend.