What is the test for a defendant to be found guilty of making a statement in a public place of public interest?

However, " '[I]t is not enough that the statement refer to a subject of widespread public interest; the statement must in some manner itself contribute to the public debate.' " (FilmOn, supra, 7 Cal.5th at p. 150, italics added.) "We are not concerned with the social utility of the speech at issue, or the degree to which it propelled the conversation in any particular direction; rather, we examine whether a defendant - through public or private speech or conduct - participated in, or furthered, the discourse that makes an issue one of public interest." (Id. at p. 151; Wilson v. Cable News Network, Inc., supra, 7 Cal.5th at p. 900.) This question requires us to consider "context - including audience, speaker, and purpose." (FilmOn, at p. 152.)

Page 10