In Beach v. Harco National Ins. Co. (2003) 110 Cal.App.4th 82, an insurance company was sued for bad faith due to its handling of an uninsured motorist claim. The Court of Appeal concluded section 425.16 was inapplicable because "the bad faith behavior ascribed to the defendant involved nonaction and delays" and because the complaint did not refer to any actionable communications. (Beach, at p. 93.) Moreover, "the outlined actions (or nonactions) occurred as part of a coverage dispute between an insurer and its insured, and occurred long before any arbitration or other proceeding commenced." (Id. at p. 94.)