In LiMandri v. Judkins (1997) 52 Cal. App. 4th 326, 345, an attorney representing clients in a lawsuit had a fee agreement granting the attorney a portion of the recovery. The defendant allegedly intentionally interfered with that contractual relationship by arranging a loan to the clients secured by the recovery and filed a notice of lien in the lawsuit asserting the lender's security interest in the recovery. The LiMandri court rejected the defendant's argument that the absolute privilege barred the attorney's claim for intentional interference with an existing contractual relationship. First, reasoned LiMandri, the privilege protects communicative acts rather than noncommunicative conduct, and therefore when a defendant engages in a course of conduct that is tortious, the fact that the conduct incidentally included a privileged communication does not permit the defendant to interpose the privilege to shield him from liability arising out of the course of conduct. (Id. at p. 345.) Second, noted LiMandri, the conduct that produced the injury was creation of the competing lien, not the assertedly privileged act of giving notice of the lien. (Ibid.) Third, LiMandri reasoned that even if the communicative conduct was the cause of the injury, the party giving notice of the lien was not a litigant or other participant authorized by law to intervene in the underlying lawsuit. Finally, even if the defendant could be deemed an authorized participant, to be privileged a communication must be connected or logically related to the litigation or engaged in for the purpose of achieving the objects of the litigation, and the notice of lien was to enforce a debt wholly unrelated to the underlying lawsuit. (Id. at pp. 345-346, 60 Cal. Rptr. 2d 539.) For all of these reasons, LiMandri concluded the privilege did not bar the plaintiff's action.