At the conclusion of the SLAPP suit, the defendant could respond by filing a new lawsuit against the SLAPP filer for malicious prosecution, abuse of process, intentional infliction of emotional distress, or other state statutory or common law claims.9 Although these causes of actions provide an avenue for victims of SLAPP suits to recover damages, numerous obstacles make these avenues undesirable. After enduring a long and costly litigation battle, a defendant in a SLAPP suit is unlikely to be capable of commencing and funding new litigation.10 Additionally, successfully litigating these common law claims places the burden of proof on the plaintiff.11 Malicious prosecution requires the plaintiff to first have the initial claim resolved in its favor.12 Many defendants in a SLAPP suit, due to the high cost, will eventually settle the lawsuit rather than continue through the finality of the case. ...anti-SLAPP statutes generally apply to causes of action that arise from the defendant's exercise of their First Amendment rights, including the freedom of speech, freedom to petition, and freedom of association.17 Second, anti-SLAPP statutes often provide for a shifting burden of proof, requiring the defendant to show that the anti-SLAPP statute applies and then shifting the burden of proof to the plaintiff to establish a prima facie case for each element of the cause of action.18 Third, many anti-SLAPP statutes provide remedies and mechanisms for relief to undermine the original plaintiff's motivation for filing a SLAPP suit. "24 Missouri and New Mexico also limit the applicability of their antiSLAPP statutes to conduct or statements "undertaken or made in connection with a public hearing or public meeting, in a quasi-judicial proceeding before a tribunal or decision-making body of the state or any political subdivision of the state.