Earl Porter sued Joseph Kidd for defamation and related claims after receiving emails about a charitable project to which Kidd had donated. Kidd moved to strike or dismiss the complaint under Georgia’s anti-SLAPP statute, but the trial court denied the motion. The Court of Appeals of Georgia held that the trial court applied the statute incorrectly, including in its treatment of Porter’s civil RICO theory and the alleged predicate acts. The demand letters could not supply the required predicate acts, and the complaint did not adequately plead reliance for fraud. The court reversed the denial of Kidd’s anti-SLAPP motion and remanded for further proceedings.