Under the 2019 Tenant Protection Act (Civ. Code 1946.2), a landlord may not terminate the tenancy of a tenant who has occupied the premises for more than 12 months absent “just cause.” Under section 1946.2(b)(1)(K), “just cause” includes the tenant failing to move out after having given the landlord written notice of the tenant’s intention to terminate the tenancy or after the tenant makes a written offer to surrender the premises which the landlord accepts. This decision holds that a standard Cal. Assn. of Realtors lease addendum under which the tenant agrees to vacate on a specified date in return for abatement of past due rent does not qualify as a notice allowing just cause termination under section 1946.2(b)(1)(K) because it was not a notice from the tenant and was not served in the manner required by Civ. Code 1946. Hence, failure to move out as agreed was not a just cause allowing termination of the tenancy or commencement of an unlawful detainer action.