What is the test for meeting the threshold burden of demonstrating that a cause of action arises from protected activity?

A defendant meets its threshold burden of demonstrating that a cause of action arises from protected activity by showing that the act or acts underlying the claim fit one or more of the four categories described in section 426.16, subdivision (e). (Navellier v. Sletten (2002) 29 Cal.4th 82, 88.) These categories include "any written or oral statement or writing" that is "made before a legislative, executive, or judicial proceeding, or any other official proceeding authorized by law" ( 425.16, subd. (e)(1)), "made in connection with an issue under consideration or review by a legislative, executive, or

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