Facts: A tenant entered into a commercial lease agreement. The agreement provided for the tenant to renew the lease, though it did not specify how many times the tenant could exercise the option to renew, and included provisions indicative of a short-term lease. The tenant renewed the lease at the end of the first term, then attempted to renew again at the end of the second term.

Claim: The landlord sought to terminate the lease, claiming he was not obligated to provide another renewal since the original lease did not explicitly offer an unlimited number of renewals, and the lease was consistent with a traditional, short-term lease, rather than a perpetual lease.

Counter claim: The tenant claimed the original lease allowed for an unlimited number of renewals since it did not directly state it would allow only one lease renewal.

Holding: A California appeals court held the landlord may terminate the lease since unlimited renewals may only be enforced if the lease demonstrates the landlord’s intent to offer unlimited renewals, which it did not as the lease included provisions typical of a short-term lease. [Ginsberg v. Gamson (April 30, 2012) _ CA3d _]