In Rohde v. Wolf (2007) 154 Cal.App.4th 28, an attorney, whose client was involved in a dispute with his sister, left a voicemail message with the sister's real estate agent before any litigation was filed. The attorney accused the sister and her agent of conspiring to defraud his client, and said he intended "to take 'appropriate action.'" (Id. at p. 36.) The sister sued for defamation, and the attorney filed a SLAPP motion. The court found the voicemail messages concerned the subject of a dispute and that considered in context, the attorney's threats to take "appropriate action" had to have been in anticipation of litigation which the attorney "contemplated in good faith and under serious consideration." (Id. at pp. 36-37.) Accordingly, the attorney satisfied the threshold step of the SLAPP analysis by establishing that his conduct was protected activity under section 425.16. (Ibid.)