What is the test for determining whether a protected activity is a cause of action?

In deciding whether a cause of action arises from protected activity, "the critical point is whether the plaintiff's cause of action itself was based on an act in furtherance of the defendant's right of petition or free speech." ( City of Cotati v. Cashman (2002) 29 Cal.4th 69, 78, 124 Cal.Rptr.2d 519, 52 P.3d 695 ( City of Cotati ), original italics.) There is "a distinction between activities that form the basis for a claim and those that merely lead to the

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