Yu

*1027 Generally, as a fundamental rule, when a civil litigant sues for monetary damages, "the amount demanded must be stated." ( Code Civ. Proc., § 425.10, subd. (a)(2).) 1 A demand for "damages according to proof" is insufficient; such a demand does not *104 provide adequate notice to sustain a default judgment. (§ 585, subds. (a) & (b).)

Here, Bann-Shiang Liza Yu hired Automatic Teller Modules, Inc. (ATMI), a general contractor, to design and build a hotel. After the hotel opened, Yu filed a complaint against ATMI for construction defects, praying for "not less than $10 million dollars" in damages. ATMI filed a cross-complaint against its subcontractors, including Fitch Construction and Fitch Plastering (collectively the Fitch Entities). ATMI's cross-complaint prayed for "compensatory damages according to proof."

Yu and ATMI settled their lawsuit. Subsequently, ATMI assigned its cross-complaint rights to Yu, who obtained a $1.2 million default judgment *1028 against the Fitch Entities. Yu then sued the alleged insurers of the Fitch Entities, in order to collect on her default judgment. But the trial court voided the underlying default judgment, finding that ATMI's…