Public distribution of a video of an altercation between two neighbors was not protected conduct under CCP 425.16(e), so the trial court properly denied the Anti-SLAPP motion filed by defendant, who had distributed the video. Neither participant in the altercation was a public figure and nothing about their fight was of public interest. Private information cannot be turned into a matter of public interest simply by the defendant’s widespread distribution of the information. Also, the public distribution was not privileged under Civ. Code 47(b) since the video was distributed to persons other than parties and other participants in the litigation.
California Court of Appeal, Second District, Division 6 (Gilbert, P.J.); April 27, 2016; 2016 WL 1702427