On remand after Bonni v. St. Joseph Health System (2021) 11 Cal.5th 995 held that 8 of Bonni’s 10 retaliation claims arose from protected activity under CCP 425.16(e), this decision holds that the absolute litigation privilege precludes Bonni from proving a probability of success on those 8 claims.  Defendant’s reports to the Medical Board are statutorily required and hence subject to the absolute litigation privilege.  Statements about Bonni’s incompetence made during peer review committee hearings on the matter are also absolutely privileged.  So is defendant’s act of initiating peer review.  Likewise, a recommendation from the hospital’s appeal committee to its board of trustee’s was subject to the absolute privilege.  In a tort claim for damages (rather than an equitable action to set a settlement aside for fraud), representations made in the course of settling a contested claim are also subject to the absolute litigation privilege.