How has the court interpreted section 425.16 of the California Code of Civil Procedure on a motion to strike?

The court held that the defendant's counseling of the tenant was "in anticipation of litigation" and was therefore protected conduct under section 425.16. ( Id. at p. 1115, 81 Cal.Rptr.2d 471, 969 P.2d 564.) The court noted that "the statute does not require that a defendant moving to strike under section 425.16 demonstrate that its protected statements or writings were made on its own behalf (rather than, for example, on behalf of its clients or the general public)." ( Id. at p. 1116, 81 Cal.Rptr.2d 471, 969 P.2d 564 ; see Ludwig v. Superior Court (1995) 37 Cal.App.4th 8, 18, 43 Cal.Rptr.2d 350 ( Ludwig ) [instigating lawsuits by others was protected conduct under section 425.16 ].)