What is the effect of false misrepresentation in the context of a public interest claim?

Defendants' alleged false representations to these plaintiffs concerned a subject that was purely private, of interest solely to the plaintiffs themselves: namely, whether plaintiffs would be risking criminal prosecution by carrying out their supposed job duties. That subject matter was not shown to be a subject of any interest to a broad segment of society. Any possible connection between those private assurances and the public's interest in either the tribe's governance and/or the tribal leadership dispute (the details of which defendants never explained) was highly attenuated, without any discernible "degree of closeness" between them. " '[A] matter of concern to the speaker and a relatively small, specific audience is not a matter of public interest.' " (Bikkina v. Mahadevan (2015) 241 Cal.App.4th 70, 82.)