While a summary adjudication motion must completely dispose of a cause of action, for these purposes “cause of action” is determined in the Pomeroy sense used for res judicata and does not depend on how claims are grouped in the complaint. Thus, where two or more separate and distinct wrongful acts are combined in the same cause of action in a complaint, a party may present a summary adjudication motion that pertains to some, but not all, of the separate and distinct wrongful acts. That is because each separate and distinct wrongful act is an invasion of a separate and distinct primary right, and each violation of a primary right is a separate and distinct “cause of action” — regardless of how the claim is presented in the complaint.” Thus, plaintiff could properly move for summary adjudication on its claim defendant breach its non-solicitation agreement by soliciting plaintiff’s clients, even though the same cause of action of the complaint also alleged breach of the same agreement by soliciting plaintiff’s employees.