dissenting.
Because I believe the decision of the Court of Appeals in this case improperly limits the scope of acts protected by OCGA § 9-11-11.1,1 must respectfully dissent to the majority’s affirmance of that decision. Berryhill’s actions in this case were to post a message on a website for families of disabled adults and to send the message by e-mail to the Atlanta Journal Constitution, regulatory personnel of the Department of Human Resources, and private individuals, complaining that her son was receiving poor treatment and care. She has contended she sent the messages in a good faith belief they would spark an investigation of her son’s care and the trial court found that her statements to regulatory personnel at the Department of Human Resources constituted petitioning the government for redress of grievances. Without any discussion of the evidence on which the trial court based that finding, and with no deference to the trial court’s findings, the Court of Appeals held that her statements could not be construed as a request for any official investigation or proceeding. A majority of this Court has now adopted that holding, still without according to the trial court’s findings the deference generally accorded to factfinders. I disagree with that holding and with the restriction of protected acts to those which are made in the context of or in pursuit of official proceedings.
To explain the restrictions it placed on the protections of the anti-SLAPP statute, the Court of Appeals made two key holdings in the decision under review. First, it held OCGA § 9-11-11.1 “defines” the acts to which the anti-SLAPP statute applies as
any written or oral statement, writing, or petition made before or to a legislative, executive, or judicial proceeding, or any other official proceeding authorized by law, or any written or oral statement, writing, or petition made in connection with an issue under consideration or review by a legislative, executive, or judicial body, or any other official proceeding authorized by law. [Cit.]
Georgia Community Support & Solutions v. Berryhill, 275 Ga. App. 189, 190 (620 SE2d 178) (2005). Second, the decision stated:
*444The anti-SLAPP statute does not encompass all statements that touch upon matters of public concern. Rather, by its terms, the statute’s application is limited to statements “made before or to a legislative, executive, or judicial proceeding, or any other official proceeding authorized by law, or any . . . statement. . . made in connection with an issue under consideration or review by a legislative, executive, or judicial body, or any other official proceeding authorized by law.” [Cit.]
(Emphasis supplied.) Id. at 192 (1). Both of those holdings narrow the scope of the anti-SLAPP statute by reading the word “includes” as an expression of limitation, a narrowing I believe was improper.
The statute protects
an act.. . which could reasonably be construed as an act in furtherance of the right of free speech or the right to petition government for a redress of grievances under the Constitution of the United States or the Constitution of the State of Georgia in connection with an issue of public interest or concern. . . .
OCGA§ 9-11-11.1 (b). Subsection (c) of the statute provides that such act
includes any written or oral statement, writing, or petition made before or to a legislative, executive, or judicial proceeding, or any other official proceeding authorized by law, or any written or oral statement, writing, or petition made in connection with an issue under consideration or review by a legislative, executive, or judicial body, or any other official proceeding authorized by law.
(Emphasis supplied.) “In all interpretations of statutes, the ordinary signification shall be applied to all words....” OCGA § 1-3-1 (b). The American Heritage Dictionary of the English Language (4th ed., 2004, Houghton Mifflin Company), includes in its definitions of the word, “include,” “To contain as a secondary or subordinate element.” In its discussion of usage, that dictionary notes that “Include often implies an incomplete listing.” Id. Black’s Law Dictionary (8th ed. 2004), contains this definition and comment:
include, vb. To contain as a part of something. The participle “including” typically indicates a partial list: the plaintiff asserted five tort claims, including slander and libel. But some drafters use phrases such as including without limitation and including but not limited to — which mean the same thing, (punctuation modified for clarity)
*445As this Court noted in Housing Auth. of City of Carrollton v. Ayers, 211 Ga. 728, 729 (88 SE2d 368) (1955), “a statutory definition of a term as ‘including’ certain things does not necessarily put a meaning thereon limited to the inclusion. [Cit.]” Similarly, the U. S. Supreme Court said in Federal Land Bank of St. Paul v. Bismarck Lumber Co., 314 U. S. 95, 100 (62 SC 1, 86 LE 65) (1941), “the term‘including’is not one of all-embracing definition, but connotes simply an illustrative application of the general principle.” The term “includes” is ordinarily a word of enlargement and not of limitation. North Carolina Turnpike Auth. v. Pine Island, Inc., 265 N.C. 109, 120 (143 SE2d 319) (1965). The Court of Appeals properly applied the word that way in the context of the anti-SLAPP statute in Chatham Orthopaedic Surgery Center v. Ga. Alliance of Community Hospitals, 262 Ga. App. 353 (1) (585 SE2d 700) (2003), where it noted that an act in furtherance of the rights of free speech or petition “ ‘includes’ (and is thus not limited to)” the specific communications listed in OCGA § 9-11-11.1 (c). The majority now disapproves of the decision in Chatham Orthopaedic Surgery Center by relegating its interpretation of the statute to the status of a dictum. However,
[a] dictum is an opinion expressed by a court, but which, not being necessarily involved in the case, lacks the force of an adjudication; an opinion expressed by a judge on a point not necessarily arising in the case; a statement or holding in an opinion not responsive to any issue and not necessary to the decision of the case; . . . [Cit.]
Cullers v. Home Credit Co., 130 Ga. App. 441, 449 (203 SE2d 544) (1973). I do not believe that an appellate court’s explanation of the scope of a statute it is construing can fairly be considered “a point not necessarily arising in the case . . .” so as to make that explanation dismissible as a dictum.
In addition to being unsupported by the language of the statute, the narrow construction of the statute approved by the majority is undesirable as a matter of public policy. Requiring that an official proceeding be underway on the subject of the statements or that the statements be successful in bringing about an official proceeding eliminates the protection needed to encourage public disclosure of wrongdoing and frustrates the General Assembly’s declared purpose in enacting the anti-SLAPP statute, “to encourage participation by the citizens of Georgia in matters of public significance through the exercise of their constitutional rights of freedom of speech and the right to petition government for redress of grievances.” OCGA § 9-11-11.1 (a). That public policy is not advanced by placing rigid restrictions on the scope of its protection so that only statements *446made directly in the course of an official proceeding or statements expressed skillfully enough and directed accurately enough that an appellate court cannot ignore their intent are within the protection of the statute.
Decided November 28, 2006 Keconsideration denied December 15, 2006. Torin D. Togut, for appellant.The limitation imposed by the decision of the Court of Appeals and approved by the majority effectively writes out of the statute the references to the right of free speech by requiring that an act entitled to protection under the statute amount to a request for government proceedings to be initiated,1 which is a petition to government for the redress of grievances. That the statute does not contain such a requirement may be seen from the fact that it twice joins the phrases “right of free speech” and “right to petition government” with the disjunctive “or.” OCGA§ 9-11-11.1 (b), (c). Had the General Assembly intended the statute to provide protection only to acts which amount to petitioning the government for redress of grievances, the phrases would have been made conjunctive, or the reference to freedom of speech would have been omitted completely. The inclusion of the phrase “right of free speech” indicates the General Assembly did not intend to limit the coverage of the statute to acts amounting to a petition to government, and the contrary holding in the decision of the Court of Appeals, approved implicitly by the majority, was incorrect.
The limitations placed on the scope of the anti-SLAPP statute by the Court of Appeals and by the majority of this Court have eviscerated the protections of the statute. Exercising one’s right of free speech on matters of public concern, and it cannot credibly be argued that matters regulated by the government are not matters of public concern, has now lost the protection intended by the General Assembly in its passage of the anti-SLAPP statute. The citizens of Georgia are the poorer for that loss, and I cannot join in an opinion which effects that deprivation. Accordingly, I must dissent.
I am authorized to state that Chief Justice Sears and Presiding Justice Hunstein join in this dissent.
*447Richard E. Witterman, Jr., for appellee. Gerald R. Weber, Jr., Elizabeth L. Littrell, Margaret F. Garrett, amici curiae.Nor is there any evidence that Berryhill sought to initiate an official proceeding by making the statements. Although she stated in her affidavit that she hoped her e-mails would prompt the Atlanta Journal-Constitution and Georgia Department of Human Resources to look into GCSS’s treatment and care of her son, nothing in the e-mails can be construed as a request for any official investigation or other proceeding.
Georgia Community Support & Solutions v. Berryhill, supra, 275 Ga. App. at 192.