In Frio v. Superior Court (1988) 203 Cal. App. 3d 1480, 1490, 250 Cal. Rptr. 819, a record producer secretly taped telephone conversations with business associates with whom he later became involved in litigation. In a pretrial order, the trial court excluded the producer's testimony about the contents of the conversations based on section 632, subdivision (d), which excludes any evidence obtained as a result of eavesdropping upon or recording a confidential communication in violation of section 632. On petition for writ review, Frio argued that conversations relating to business matters could not reasonably be considered confidential. The court disagreed: "Because Frio's business involved a few key people, a highly visible product and the potential for substantial profit, there is every reason to believe each of the tape recorded parties reasonably expected their communications would not be simultaneously disseminated to an unannounced second auditor. All the telephone communications were conducted on a one-on-one basis and related to a profitable venture which the speaker reasonably might expect would be confined to the parties . . . . In sum, under section 632 'confidentiality' appears to require nothing more than the existence of a reasonable expectation by one of the parties that no one is 'listening in' or overhearing the conversation. Clearly, the communications in issue meet this threshold standard." ( Id. at p. 1489-1490.)