What is the test for a defendant to refuse to contest an action?

A complaint must contain "[a] demand for judgment for the relief to which the pleader claims to be entitled." ( 425.10, subd. (a)(1).) In general, if the complaint demands "the recovery of money or damages..., the amount demanded shall be stated." (Id., subd. (a)(2).) Section 580, subdivision (a) provides in relevant part that "[t]he relief granted to the plaintiff, if there is no answer, cannot exceed that demanded in the complaint...."³ Section 580 and related sections "aim to ensure that a defendant who declines to contest an action does not thereby subject himself [or herself] to open-ended liability." (Greenup v. Rodman (1986) 42 Cal.3d 822, 826 (Greenup).)"[T]he primary purpose of [section 580] is to guarantee defaulting parties adequate notice of the maximum judgment that may be assessed against them." (Ibid.)"[N]otice enables a defendant to exercise his right to choose... between (1) giving up his right to defend in exchange for the certainty that he cannot be held liable for more than a known amount,

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