Does the submission of an insurance claim constitute protected pre-litigation activity under the anti-SLAPP statute?

Waveform relies on cases such as People ex rel. Fire Ins. Exchange v. Anapol (2012) 211 Cal.App.4th 809, to support its contention. There, the appellate court held that whether the submission of an insurance claim constituted protected pre-litigation activity under the anti-SLAPP statute depended on whether the claim is submitted for payment, or merely as a necessary precursor to litigation. It also held that in most cases in that process litigation would be a "mere possibility"which is not sufficient to consider the insurance claims process formal pre-litigation conductand thus it is not an "official proceeding." (Id. at p. 827.)