Does the anti-SLAPP provisions of the California Anti-Pornography Act apply to a defendant in an ordinary private dispute?

Notwithstanding the anti-SLAPP statute must be construed broadly (Martinez v. Metabolife Internat., Inc. (2003) 113 Cal.App.4th 181, 187), its boundaries are not limitless. "[A] defendant in an ordinary private dispute cannot take advantage of the anti-SLAPP statute simply because the complaint contains some references to speech or petitioning activity by the defendant. [Citation.] . . . [W]hen the allegations referring to arguably protected activity are only incidental to a cause of action based essentially on nonprotected activity, collateral allusions to protected activity should not subject the

Page 10