Does the discovery rule apply against non-mass media defendants whose defamatory statements were republished in the media?

From a practical point of view, applying the discovery rule to claims against non-mass media defendants, whose defamatory statements were republished in the mass media, should be no more difficult than applying it in the other situations in which it arises. The trier of fact will simply consider the evidence as to the delayed discovery, and decide whether plaintiff's reasons therefore are believable. The fact that a defamatory comment has been published in the mass media, as well as the nature of the media - a daily newspaper, a slim volume of self-published poetry, a high school play -- will all be factors relevant to whether a plaintiff knew or should have known he or she had a cause of action. (See, e.g., McKelvey v. Boeing of North American, Inc. (1999) 74 Cal.App.4th 151, 160-161 [when plaintiffs knew of public notices and newspaper articles that contained information about defendant's intentional, reckless and negligent conduct, it was incumbent upon them to allege facts showing why these items did not put them on notice for purposes of the accrual of a cause of action].) In other words, the fact that the defamatory statement was known to large segments of the general population would relate to whether the trier of fact believed a plaintiff who claimed not to have discovered the libel or slander until sometime after it was first published in the mass media.