Nguyen v. Proton Technology Corp. (1999) 69 Cal. App. 4th 140, involved a prelitigation demand letter sent by one company (Proton) to another (Excelsior), accusing the latter of unfair competition for raiding Proton's employees. In addition, it accused Nguyen, a former Proton sales representative then working for Excelsior, of soliciting Proton's customers to switch their business to Excelsior. The letter went on: " 'We think you should be aware . . . ' " that Nguyen had been in prison " 'for repeatedly and violently assaulting his wife.' " ( Id. at pp. 143-144.) (In fact, Nguyen had been in county jail for shooting at an unoccupied vehicle and vandalism.) Nguyen sued Proton for defamation and other related causes of action. The trial court granted Proton's motion for summary judgment on the ground Proton's statements were absolutely protected by the litigation privilege. Nguyen appealed, and the appellate court reversed. The court concluded Silberg v. Anderson (1990) had significantly limited what was becoming a fairly expansive view of the "logical relation" test, and thereby brought the test more into line with several earlier decisions, including notably Carney and Kinnamon (cases disapproved expressly or inferentially by Silberg on other grounds as noted above). "We think these cases, and several others discussed earlier, establish an important point for both litigants and attorneys concerning prelitigation demands and the like. That point is that section 47(b) does not prop the barn door wide open for any and every sort of prelitigation charge or innuendo, especially concerning individuals." ( Nguyen v. Proton Technology Corp., supra, 69 Cal. App. 4th at p. 150.) Accordingly, the court said: "We have no difficulty in holding that the inclusion in Proton's demand letter to Excelsior of references to Nguyen's criminal record falls outside of the section 47(b) privilege." ( Id. at p. 151.) This was so, it explained, partly because the information was incorrect, but more importantly because any connection between Nguyen's criminal record and Excelsior's alleged acts of unfair competition was "to be charitable about it, tenuous." (Ibid.)