Does a plaintiff have to plead both protected and unprotected claims in a motion to strike?

City of Colton v. Singletary (2012) 206 Cal.App.4th 751, 774, 142 Cal.Rptr.3d 74.) Unfortunately, absent further guidance to litigants as to how claims must be alleged and/or how special motions to strike must be framed, the protections of the anti-SLAPP law may still be circumvented by the inartful pleading of claims (deliberately or innocently) that allege both protected and unprotected activity. Accordingly, we hold that, under the facts of this case (where the plaintiff has not specifically asked for relief as to some specified unprotected conduct that is a subpart of a cause of action), the principal thrust/gravamen analysis remains a viable tool by which to assess whether a plaintiff's claim arises out of protected activity.

c. The defendant's burden