California, United States of America
The following excerpt is from Bellino v. Tamra, G057450 (Cal. App. 2020):
To meet its burden on the second prong, a plaintiff must show the cause of action has "minimal merit." (Navellier v. Sletten (2002) 29 Cal.4th 82, 88-89.) "Slander is a species of defamation. . . . 'A false and unprivileged oral communication attributing to a person specific misdeeds or certain unfavorable characteristics or qualities, or uttering certain other derogatory statements regarding a person, constitutes slander.'
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