In Foothills Townhome Assn. v. Christiansen (1998) 65 Cal.App.4th 688, a homeowners association sued one of its members demanding payment of a special assessment. The court denied the member's anti-SLAPP motion against the association, stating: "When considering a section 425.16 motion, a court must consider the actual objective of the suit and grant the motion if the true goal is to interfere with and burden the defendant's exercise of his free speech and petition rights." (65 Cal.App.4th at p. 696.) Since the member had not met his burden of proving the association brought suit for the purpose of interfering with the member's free speech rights, the trial court denied the motion, and the court of appeal affirmed. (Ibid.) This argument was rejected in Fox Searchlight Pictures, Inc. v. Paladino (2001) 89 Cal.App.4th 294. The court reasoned: "The opinions cited in Foothills Townhome do not support its holding. In Wilcox v. Superior Court, we observed section 425.16 'is limited to exposing and dismissing . . . lawsuits "brought primarily to chill the valid exercise of the constitutional rights of freedom of speech and petition for the redress of grievances". . . .' However, in explaining the moving party's burden of proof we stated: 'The statute requires the defendant to make a prima facie showing the plaintiff's suit arises "from any act of defendant in furtherance of defendant's right of petition or free speech under the United States or California Constitution in connection with a public issue."' Nothing in our opinion can be construed to hold the moving party must prove the lawsuit was 'brought primarily' to chill its First Amendment rights." ( Id. at p. 306.)