(Plaintiff’s letter written to defendant’s HR department shortly before plaintiff sued for wrongful termination was protected activity under CCP 415.16(e). Plaintiff’s boss failed to show that the letter fell within the narrow Flatley v. Mauro (2006) 39 Cal.4th 299 exception for patently illegal conduct. Here, plaintiff disputed the boss’ assertion that plaintiff had threatened to defame him to his superiors unless he promoted her. And the evidence produced on the motion and sketchy arguments in the boss’ briefs didn’t establish beyond question that plaintiff had committed any crime in sending the letter.)