JOHN DOE 2, Petitioner, v. THE SUPERIOR COURT OF LOS ANGELES COUNTY, Respondent; AVONGARD PRODUCTS U.S.A. LTD., Real Party in Interest., 1 Cal. App. 5th 1300

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HOLDINGS: [1]-Anonymous emails regarding common ownership of companies were not actionable as libel under Civ. Code, § 44, because language such as "bad business practices" was too vague to be read as an accusation of specific wrongdoing, the emails made extensive use of cautionary language indicative of constitutionally protected opinions rather than facts, the author did not claim superior knowledge or expertise, and statements about ownership of one company were not reasonably susceptible of an interpretation implying any undisclosed false and defamatory fact of and concerning another company; [2]-Absent a prima facie showing of libel, the author's identity was not subject to special discovery under Code Civ. Proc., § 425.16, subd. (g), in opposing an anti-SLAPP motion; [3]-The possibility of an arbitration agreement provided no basis for discovery without evidence of its provisions.