In Cotati v. Cashman (2002) 29 Cal.4th 69, mobile home park owners brought an action in federal court challenging the legality of the city's rent control ordinance. The city filed an action for declaratory relief in state court, based on the same underlying issues. The owners moved to strike the city's state court complaint as a SLAPP action. The city conceded that its purpose in filing the state court action was to gain a more favorable forum to litigate the constitutionality of its ordinance. (Id. at pp. 72-73.) The Supreme Court held that even in these circumstances the city's state court action did not fall within the SLAPP statute. Construing the statute, the court held that the city's state court action did not arise from the owners' filing of the federal court action, within the meaning of the statute. (Cotati, supra, 29 Cal.4th at pp. 76-78.) Rather, it arose from the underlying dispute about the constitutionality of the ordinance. (Id. at pp. 79-80.) The Supreme Court commented, "The mere fact an action was filed after protected activity took place does not mean it arose from that activity. . . .. . .To construe 'arising from' in section 425.16, subdivision (b)(1) as meaning 'in response to,' as Owners have urged, would in effect render all cross-actions potential SLAPP's. We presume the Legislature did not intend such an absurd result." (Id. at pp. 76-77.) It added, "Just as a cross-complaint often 'arises out of the same transaction, occurrence, or series of transactions or occurrences as the cause of action which the plaintiff alleges' , so may a responsive but independent lawsuit arise from the same transaction or occurrence alleged in a preceding lawsuit, without necessarily arising from that earlier lawsuit itself citing Church of Scientology v. Wollersheim, 42 Cal.App.4th 628, 651." (Cotati, supra, 29 Cal.4th at p. 78.) The court concluded that the City's alleged subjective intent to coerce settlement by forcing the owners to litigate in two different jurisdictions "is not relevant under the anti-SLAPP statute. As a corollary, a claim filed in response to, or in retaliation for, threatened or actual litigation is not subject to the anti-SLAPP statute simply because it may be viewed as an oppressive litigation tactic." (Ibid.)