California, United States of America
The following excerpt is from Freidberg v. Bardis, C086920 (Cal. App. 2019):
In making a prima facie showing at the first step, "it is not enough to establish that the action was filed in response to or in retaliation for a party's exercise of the right to petition. [Citations.] Rather, the claim must be based on the protected petitioning activity. [Citation.]" (Drell v. Cohen (2014) 232 Cal.App.4th 24, 29.)
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