In addition, “the Tribunal`s findings of fact relating to an application for the execution of a transaction pursuant to section 664.6 are subject to limited appeal review and are not disturbed if supported by substantial evidence.” [Omitted the quote. (Osumi v. Sutton (2007) 151 Cal.App.4th at 1360.) The following provisions are really “general” because they are generally not subject to negotiation, but they are important to include in most, if not all, comparisons, in order to enhance security and applicability: the problem of enforcing a settlement agreement entered into or out of a courtroom is as old as the settlement agreements themselves. Prior to 1981, the law was unclear what the parties could do to impose settlement agreements and how they would have to proceed if they wanted to enforce such an agreement. Several cases proposed a large number of alternatives to implementation, some of which were contradictory. Thus, some cases indicated that enforcement could be obtained by summary judgment or by amending the pleadings (appearance as a positive claim or defence) in the underlying case, while others required a separate equity action. See Duran vs. Duran (1983) 150 CA3d 176, 179, 197 CR 497. However, for many years it has been considered that efforts to enforce comparisons on the basis of facts outside of briefs must be regarded as motions for summary judgment that can only be satisfied without valid factual questions. See Hastings v Matlock (1980) 107 CA3d 876, 881, 166 CR 229. But this view was not unanimous. .