In Taus v. Loftus (2007) 40 Cal.4th 683, the plaintiff sued, among others, the authors of several articles on recovered memory of child abuse for negligent infliction of emotional distress, invasion of privacy, fraud, and defamation. The defendants filed an anti-SLAPP motion to strike the entire pleading. Relevant to the inquiry in the instant appeal, we focus on the Supreme Court's analysis of the invasion of privacy cause of action. Noting that this cause of action was based on two theories, public disclosure of private facts and intrusion into private matters, it found protected activity as to the former, but not the latter, where the plaintiff alleged that "defendants employed fraudulent means to obtain private information from plaintiff's relatives, including misrepresenting their identity and befriending plaintiff's biological mother." (Taus, supra, 40 Cal.4th at p. 701.) The Taus court then struck all allegations except those relating to obtaining private information by fraudulent means. (Id. at p. 742.)