In Philipson & Simon v. Gulsvig (2007) 154 Cal.App.4th 347, a client initiated fee arbitration because his lawyers retained $ 15,000 in settlement funds for their fees, pursuant to the settlement agreement. (Id. at pp. 352-253.) In later litigation regarding the settlement, the law firm brought a cross-complaint against its (now former) client, alleging the client breached the retainer agreement by refusing to allow it to keep its fees. (Id. at p. 355.) The court held the firm's claim was subject to an anti-SLAPP motion because it was based on the client's protected act of commencing fee arbitration. (Id. at pp. 360-361.) It embraced the client's contention that her bare refusal to pay would have been unprotected if "she was ever in possession of the disputed $ 15,000." (Id. at p. 360.) But because the client had never received the settlement amount allocated to legal fees, "she could not 'refuse' to pay it other than" by initiating arbitration, and so the firm's claim arose from that protected activity. (Id. at p. 361.)