California, United States of America
The following excerpt is from Hui v. Huang, B279426 (Cal. App. 2018):
Nor can an individual accused of making defamatory statements by her "'own conduct, create [her] own defense by making the claimant a public figure.' (Hutchinson v. Proxmire [(1979)] 443 U.S. [111,] 135, 99 S.Ct. [2688,] 61 L.Ed.2d [411,]
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