Court of Appeal (Cal.) Holds that Litigation Privilege Does Not Trump UCL Claim Grounded on Rosenthal Act

In People v. Persolve, (2013) 2013 DAR 10915, the Court of Appeal held that the litigation privilege is not a defense to a UCL action brought to enjoin business practices made unlawful by a statute more specific than Civil Code 47(b).  So, in this case, the People stated a good UCL claim against a debt collector for alleged unlawful business practices violating the FDCPA and Rosenthal FDCPA by collection letters and other conduct that otherwise would fall within the scope of the litigation privilege.