For Whom the Cross-Claim Tolls

ZF Micro Devices, Inc. v. TAT Capital Partners, Ltd., No. H040776 (as modified Nov. 30, 2016)

This case deals with an interesting issue on the statute of limitations. To what cross-claims does the relation-back doctrine apply to toll a limitations period? Does it only apply to compulsory cross-claims, or to permissive ones too?