In All One God Faith, Inc. v. Organic & Sustainable Industry Standards, Inc. (2010) 183 Cal.App.4th 1186, a mutual benefit trade association whose members consisted of " 'large, global brands and private label manufacturers of beauty and personal care products to small, specialty brands, raw ingredient manufacturers, and ingredient suppliers' " sought to develop an "organic" certification for use by its members with their personal care products. (All One God Faith, supra, 183 Cal.App.4th at p. 1194.) A nonmember competitor sued, arguing that the certification was contrary to federal standards for the term "organic," and thus the certification would constitute false advertising. (Id. at p. 1192.) The trade association filed an anti-SLAPP motion, which the trial court denied on the basis that the association had failed to meet its threshold burden of demonstrating that the commercial speech was protected under the anti-SLAPP statute. The court also concluded that the commercial speech exemption did not apply. (Id. at pp. 1197-1198.) Both parties appealed. The appellate court first affirmed the order denying the trade association's anti-SLAPP motion, concluding that the certification was purely commercial speech not protected under the anti-SLAPP statute. (Id. at pp. 1197-1198, 1210.) The court went on to hold that because the trade association did not produce or manufacture any cosmetic or personal care products, but acted only on behalf of its members who sold such goods, it was not "'a person primarily engaged in the business of selling or leasing goods or services.' " (Id. at p. 1218.) Thus, the commercial speech exemption in section 425.17 did not apply. (183 Cal.App.4th at p. 1218.)