The Court's opinion in People ex rel. Gallegos v. Pacific Lumber Company, ___ Cal.App.4th ___ (Jan. 10, 2008) (First Appellate District, Division Three) contains a very interesting discussion of the interplay between the UCL and the litigation privilege of Civil Code section 47(b). The leading case on that issue is Rubin v. Green, 4 Cal.4th 1187 (1993), in which the Supreme Court held that section 47(b) created a safe harbor for litigants against private UCL claims. In Pacific Lumber, the Court of Appeal held that the safe harbor should also apply to UCL claims brought by public prosecutors. Slip op. at 5-13.