No, the TCPA doesn’t apply to that either.

“We conclude the definition of ‘legal action’ in the TCPA does not encompass a motion for sanctions alleging discovery abuse by a party that is filed after, and in this case years after, the commencement of litigation. Further, construing the TCPA to apply to such a motion would open the floodgates to serial motions to dismiss during the pendency of litigation based on conduct ancillary to the substantive claims in the case.” Misko v. Johns, No. 05-18-00487-CV (May 1, 2019).