In a companion case decided on April 24, 2015, the Texas Supreme Court held that the Texas Citizens Participation Act (Act) can apply to private as well as public communications. In its per curiam opinion in Lippincott and Parks v. Whisenhunt, the Court held that controversial private communications on a matter of public concern, here the adequacy of medical services, can also trigger the protective provisions of the Act. Ultimately, the allegation made in the complaint must be measured against the evidentiary standards clarified in the decision in In re: Steven Lipsky.