The First Appellate District affirmed a judgment. The court held that a lumber company was immune under the litigation privilege from liability for violating the Unfair Competition Law by submitting allegedly fraudulent data during administrative proceedings pursuant to the California Environmental Quality Act.

In a 1996 agreement between The Pacific Lumber Company, the State of California, and the federal government, known as the Headwaters Agreement, Pacific Lumber agreed to sell the ancient-redwood Headwaters Forest to the state and federal governments.