In McConnell v. Innovative Artists Talent and Literary Agency, Inc. (2009) 175 Cal.App.4th 169, wrongful termination and retaliation claims arose from and were based on the employer's "temporary modification" of job duties, which effectively prevented the plaintiffs from performing their job as talent agents. (Id. at p. 181.) The appellate court held the facts that the modification was communicated in writing and came immediately after lawsuits were filed (by the talent agents seeking to terminate their contracts) did not convert the adverse employment action into protected activity. (Ibid.)