A defendant that files an Anti-SLAPP motion to strike under CCP 425.16 may seek attorney fees (based on prevailing on the Anti-SLAPP motion) in one of three ways:  as part of the Anti-SLAPP motion, by a post-judgment memorandum of costs, or by a post-judgment motion for an attorney fee award.  This decision holds that if the defendant chooses either of the latter two alternatives, the trial court need not (and indeed cannot) rule on  the Anti-SLAPP motion if the plaintiff voluntarily dismisses the action before the Anti-SLAPP motion is heard.  However, even after the voluntary dismissal, the trial court retains jurisdiction to rule on liability for attorney fees and so can entertain and rule on a timely filed memorandum of costs or attorney fee motion, and as part of its ruling on either of those items, the trial court must determine whether the defendant was the prevailing party on the Anti-SLAPP motion–effectively deciding how it would have decided the Anti-SLAPP motion had the plaintiff not voluntarily dismissed the action.