SAN FRANCISCO - Because a negative review of an apartment complex can be construed as containing factual assertions in addition to opinions, a California appeals panel on July 30 upheld a lower court's denial of the defendant's motion to strike under the state's anti-SLAPP (strategic lawsuit against public participation) statute (Bently Reserve L.P., et al. v. Andreas G. Papaliolios, No. A136191, Calif. App., 1st Dist., Div. 1; 2013 Cal. App. LEXIS 601).