(United States Ninth Circuit) – In an insurer-plaintiff’s suit alleging defendant, who was Cumis counsel for plaintiff’s insured, for declaratory judgment, unjust enrichment, breach of Cal.Civ. Code section 2860(d), and concealment, the District Court’s denial of defendant’s anti-SLAPP motion to strike plaintiff’s second amended complaint is affirmed where because plaintiff’s causes of action were not based on an act in furtherance of defendant’s right of petition or free speech, they did not ‘arise from’ protected activity.