To be protected speech under CCP 425.16(e)(2), a pre-litigation communication must be connected with, or have some logical relation to litigation that is contemplated in good faith and under serious consideration. Here, most of the emails an estranged former wife sent her ex-husband did not relate to the RICO suit she threatened to file against him. Three of the emails did relate to that contemplated suit which had gotten to the stage of a draft complaint. Those three were protected. However, the ex-husband showed a reasonable probability of prevailing on his claim for a Domestic Violence Protective Order stopping ex-wife from sending him more emails. The litigation privilege does not apply to DVRO claims since its purpose would not be served in that context. Non-physical “violence” can support a DVRO. And, ex-wife’s email campaign was designed to cause emotional harm. Since ex-husband showed a reasonable probability of success, the ex-wife’s Anti-SLAPP motion to strike was properly denied.