In Church of Scientology v. Wollersheim (1996) 42 Cal.App.4th 628, the appellant filed an action to set aside a judgment obtained in a prior action. When the appellant's equitable action to set aside the judgment was dismissed pursuant to section 425.16, the appellant appealed and argued that the statute was not triggered because a judgment rather than a person was being attacked. (Church of Scientology, supra, at p. 648.) According to the appellant, its complaint did not "'arise' from any act in furtherance of the respondent's right of petition or free speech because the appellant did not challenge the respondent's right to file a lawsuit nor was its lawsuit 'brought primarily to chill the valid exercise' of that right." (Ibid.) Upon analyzing the language in section 425.16, Church of Scientology concluded that the language "literally applies to any direct attack on the judgment in the prior action, which resulted from the respondent's petition activity." (Church of Scientology, at p. 648.) The church's complaint sought to set aside a prior judgment Wollersheim had obtained against the church in a prior action. The trial court dismissed the church's complaint under section 425.16, and the Court of Appeal affirmed on the grounds that the church's complaint fell within the protection of section 425.16 because it challenged Wollersheim's petition activity (the prior action and judgment) and the church failed to establish a probability of success on the merits. (Church of Scientology, supra, 42 Cal.App.4th at pp. 649, 655.) The Court of Appeal in Church of Scientology discussed the issue of compulsory cross-complaints in response to the church's argument that a broad application of section 425.16 to all litigation activity would subject all cross-complaints to a special motion to strike. The court rejected such a proposition, pointing out that "only those cross-complaints alleging a cause of action arising from the plaintiff's act of filing the complaint against the defendant and the subsequent litigation would potentially qualify as a SLAPP action." (Church of Scientology, supra, 42 Cal.App.4th at p. 651.)