In Jarrow Formulas, Inc. v. LaMarche (2003) 31 Cal.4th 728, the California Supreme Court held that a malicious prosecution action predicated upon the prior filing of a civil lawsuit fell within the ambit of the anti-SLAPP statute. The court reasoned in that context a malicious prosecution "action arises from an underlying lawsuit, or petition to the judicial branch. By definition, a malicious prosecution suit alleges that the defendant committed a tort by filing a lawsuit. " (Id. at pp. 734-735.) The court agreed with the Courts of Appeal that had reached a similar conclusion. (Ibid.) The California Supreme Court unambiguously held a malicious prosecution action "falls within the ambit of a 'cause of action against a person arising from any act . . . in furtherance of the person's right of petition' ( 425.16, subd. (b)(1)), as statutorily defined." (Id. at p. 734.) Simply put, "malicious prosecution causes of action fall within the purview of the anti-SLAPP statute. " (Id. at p. 735.) Nonetheless, Reda persists that his malicious prosecution action was not subject to an anti-SLAPP motion because the underlying litigation (specifically the third cause of action of the Globalist action) did not involve a matter of public interest-it was just a breach of contract claim. Again, he ignores Jarrow. The Supreme Court stated in Jarrow that with respect to the first "protected activity" prong of the analysis under section 425.16, "on the basis of the statute's plain language . . . a defendant moving specially to strike a cause of action arising from a statement or writing made in connection with an issue under consideration in a legally authorized official proceeding need not separately demonstrate that the statement or writing concerns an issue of public significance. " (Id. at pp. 733-734.) The California Supreme Court explained that even a claim that appears to be legally tenable when filed may ultimately fail "for reasons having to do with the sufficiency of the evidence actually adduced as the litigation unfolds." (Ibid.) The probable cause inquiry must deal with whether, at the time the claim was filed, "any reasonable attorney would have thought the claim tenable." (Ibid.) The California Supreme Court extended its holdings in Navellier v. Sletten (2002) 29 Cal.4th 82, and its previous SLAPP cases to a malicious prosecution action, holding that such an action is also within the scope of the anti-SLAPP statute so long as it could be demonstrated that the malicious prosecution action itself arose from or was based on any statement or writing made in a judicial or other official proceeding, or in connection with an issue under consideration or review by a judicial body. (Jarrow, supra, 31 Cal.4th at pp. 733-734.) In applying the "arising from" requirement of the anti-SLAPP statute to this particular cause of action, the Supreme Court stated it was "not disputed" that "by its terms, Code of Civil Procedure section 425.16 potentially may apply to every malicious prosecution action, because every such action arises from an underlying lawsuit, or petition to the judicial branch. By definition, a malicious prosecution suit alleges that the defendant committed a tort by filing a lawsuit. Accordingly, every Court of Appeal that has addressed the question has concluded that malicious prosecution causes of action fall within the purview of the anti-SLAPP statute. " (Id. at pp. 734-735.) In addition, the Supreme Court specifically noted the fact "that the underlying action was a cross-complaint rather than an original complaint is not statutorily significant as, 'for purposes of this section, "complaint" includes "cross-complaint . . . ." ' 425.16, subd. (h).)" (Jarrow, supra, 31 Cal.4th at p. 735, fn. 2.)