What constitutes protected activity under the anti-SLAPP statute?

We must first determine whether any of "defendant's act[s] underlying the plaintiff's cause[s] of action" constitutes protected activity. (City of Cotati v. Cashman (2002) 29 Cal.4th 69, 78 (City of Cotati).) Protected activity under the anti-SLAPP statute includes "any act" that is "in furtherance of " a defendant's free speech or petitioning rights, including "any written or oral

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statement or writing made before a . . . judicial proceeding." ( 425.16, subd. (e); see City of Montebello v. Vasquez (2016) 1 Cal.5th 409, 422.) " 'Any act' includes communicative conduct such as the filing, funding, and prosecution of a civil action." (Rusheen, supra, 37 Cal.4th at p. 1056, italics added, citing Ludwig v. Superior Court (1995) 37 Cal.App.4th 8, 17-19 (Ludwig).)