In A.F. Brown Elec.Contractor, Inc. v. Rhino Elec. Supply, Inc. (2006) 137 Cal.App.4th 1118, a supplier asserted claims against a contractor for alleged amounts due, including filing a negative credit report. (A.F. Brown, supra, 137 Cal.App.4th at p. 1123.) The contractor sued the supplier for libel, slander and unfair business practices. (Ibid.) The trial court denied the supplier's anti-SLAPP motion and the Court of Appeal affirmed, ruling that the supplier's communications were not protected because they were not made in contemplation of litigation or as part of an official proceeding. (Id. at pp. 1123, 1125-1130.)