The trial court correctly denied defendant’s Anti-SLAPP motion in this qui tam insurance fraud action against a doctor for preparing fraudulent patient medical reports and billing statements in support of insurance claims. The billing statements and medical reports were prepared in the ordinary course of the doctor’s business and not in serious contemplation of lawsuits, so they were not protected activity under CCP 425.16(e). (See People ex rel. 20th Century Ins. Co. v. Building Permit Consultants, Inc. (2000) 86 Cal.App.4th 280, 283-284 (submission of ordinary insurance claim is not a protected act in furtherance of eventual litigation on the insurance policy); People ex rel. Fire Ins. Exchange v. Anapol (2012) 211 Cal.App.4th 809 (submission of insurance claim is not protected right to petition activity.