In Cho v. Chang (2013) 219 Cal.App.4th 521, the plaintiff sued the defendant for, among other causes of action, sexual harassment. The defendant cross-claimed, alleging defamation and intentional infliction of emotional distress based on statements the plaintiff made to the Equal Employment Opportunity Commission and California's Department of Fair Employment and Housing in obtaining her right-to-sue letter and statements to her coworkers. The plaintiff filed an anti-SLAPP motion as to the cross-complaint. The Cho court affirmed the trial court's grant of the anti-SLAPP motion as to the allegations about the statements made to the governmental entities and denial of the motion as to the allegations about statements made to coworkers. (Cho, at pp. 527-528.) The Cho court acknowledged Taus and Oasis, but observed that neither "is a mixed cause of action." (Cho, supra, 219 Cal.App.4th at p. 527.) Eschewing a "broad" reading of Oasis, the appellate court counseled that "the guiding principle in applying the anti-SLAPP statute to a mixed cause of action case is that 'a plaintiff cannot frustrate the purposes of the SLAPP statute through a pleading tactic of combining allegations of protected and nonprotected activity under the label of one "cause of action."' ." (Cho, at p. 527.) Where each cause of action combined allegations of conduct that is protected by section 425.16 with conduct that is not, "the better view in such a case is that the trial court may strike the allegations ... attacking the protected activity while allowing the unprotected theories to remain." (Cho, at p. 523.) Cho cited the policy of the anti-SLAPP statute and section 436 to conclude that it "would make little sense if the anti-SLAPP law could be defeated by a pleading ... in which several claims are combined into a single cause of action, some alleging protected activity and some not." (Cho, supra, 219 Cal.App.4th at p. 527.) "Striking the entire cause of action would plainly be inconsistent with the purposes of the statute. Striking the claims that invoke protected activity but allowing those alleging nonprotected activity to remain would defeat none of them. Doing so also is consonant with the historic effect of a motion to strike: 'to reach certain kinds of defects in a pleading that are not subject to demurrer.' (See 5 Witkin, Cal. Procedure (5th ed. 2008) Pleading, 1008, p. 420.)" (Cho, supra, 219 Cal.App.4th at p. 527 referring to Witkin's discussion of motions to strike under 435 and 436.)