Haas

INTRODUCTION

This is the second appeal arising from the trial court’s denial of a special motion to strike under Code of Civil Procedure section 425.16 brought by Brittany Littleton based on allegations she made certain representations on social media relating to a pet dog taken from Elliott Haas, and that she raised money for her charity based on those representations.1 Littleton argues Haas’s cause of action under the unfair competition law (UCL; Bus. & Prof. Code, § 17200) arose from statements requesting funds for legal defense, which qualifies as protected litigation activity under section 425.16. We affirm.

FACTUAL AND PROCEDURAL BACKGROUND

A. Haas’s Complaint, Littleton’s First Anti-SLAPP Motion, and Related Appeal In 2020, Haas sued Littleton and Littleton’s animal rescue organization, Little Love Rescue.2 His complaint alleged causes of action for trespass to chattels, conversion, receipt of stolen property, violation of the UCL, and intentional infliction of emotional distress. As relevant here, the UCL cause of action alleged that Littleton and Little Love Rescue misrepresented on social media that they rightfully possessed his dog; misrepresented the dog’s…