In Mendoza v. ADP Screening & Selection Services, Inc. (2010) 182 Cal.App.4th 1644, the Court expressly rejected the plaintiff's contention "that every violation of a statutory prohibition necessarily removes the violator out from under the protective umbrella of the anti-SLAPP statute." (Id. at p. 1653.) Mendoza explained: "Our reading of Flatley v. Mauro (2006) leads us to conclude that the Supreme Court's use of the phrase 'illegal' was intended to mean criminal, and not merely violative of a statute. First, the court in Flatley discussed the attorney's underlying conduct in the context of the Penal Code's criminalization of extortion. Second, a reading of Flatley to push any statutory violation outside the reach of the anti-SLAPP statute would greatly weaken the constitutional interests which the statute is designed to protect. As the defendant correctly observes, a plaintiff's complaint always alleges a defendant engaged in illegal conduct in that it violated some common law standard of conduct or statutory prohibition, giving rise to liability, and we decline to give plaintiffs a tool for avoiding the application of the anti-SLAPP statute merely by showing any statutory violation." (Mendoza, supra, 182 Cal.App.4th at p. 1654.)