person communications between Mr. Snepp and Michael Roth, the group‟s media relations vice president. Further, in her December 7, 2006 letter, Ms. Domintz invited Mr. Fikre to submit any additional information he deemed appropriate and to speak directly with station employees. Ms. Domintz denied the report contained any unsubstantiated allegations and reiterated her view that the station had acted fairly and was committed to providing accurate reporting. Ms. Domintz‟s letter reiterated the fact nothing in her letter constituted an admission or waiver. Also, on December 18, 2006, Mr. Mallen sent another letter to Ms. Domintz which stated in part: “First, one of KNBC-TV‟s principal sources, Alfred Babayans, is a former Building and Safety employee who the City of Los Angeles has confirmed was terminated for cause. Contrary towhich relates to the promotional segment. After the December 19, 2006 broadcast, on January 4, 2007, a retraction demand was served by Mr. Langberg and Ms. Drooz. The January 4, 2007 retraction demand, which relates to the December 19, 2006 broadcast, begins, “This firm represents L.A. Arena Company, owner and operator of STAPLES Center.” The January 4, 2007 retraction demand makes no reference to the group. Likewise, the May 15, 2007 retraction demand, made in connection with the posting to the transcript of the December 19, 2006 broadcast on the station‟s Website makes no reference to the group; only to the arena. No retraction demand was served in connection with the May 17, 2007 internet posting. Thus, defendants assert the special motion to strike the second complaint should