Who is Vexatious Litigant Under California Law?

This case interpreted Section 391(b)(1) of the California Code of Civil Procedure, which provides a 'vexatious litigant' is one who in the past 7 years has commenced, prosecuted, or maintained at least 5 in pro per litigations (other than small claims actions) which cases were resolved adversely to the claimant, or remained pending in court unjustifiably for at least two years. (Source: http://www.metnews.com)
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