The trial court correctly denied defendant’s Anti-SLAPP motion. Plaintiff, a celebrity, alleged that Mathews, a private eye, hired by Bauer, a tabloid publisher, had illegally installed a tracking device on the car driven by plaintiff’s caretaker. Though news gathering efforts are protected speech under CCP 425.16(e), here Bauer denied that it authorized placing the tracking device, so it couldn’t claim that Mathews had placed the device as part of a news gathering effort. Furthermore, it was uncontested that placing the device on the car was illegal, so the case fell within the exception created by Flatley v. Mauro (2006) 39 Cal.4th 299.