California, United States of America
The following excerpt is from Rand Res., LLC v. City of Carson, 203 Cal.Rptr.3d 46, 247 Cal.App.4th 1080 (Cal. App. 2016):
interest should be something of concern to a substantial number of people. [Citation.] Thus, a matter of concern to the speaker and a relatively small, specific audience is not a matter of public interest. [Citations.] Third, there should be some degree of closeness between the challenged statements and the asserted public interest [citation]; the assertion of a broad and amorphous public interest is not sufficient [citation]. Fourth, the focus of the speaker's conduct should be the public interest rather than a mere effort to gather ammunition for another round of [private] controversy.... [Citation.] ... A person cannot turn otherwise private information into a matter of public interest simply by communicating it to a large number of people. (Weinberg v. Feisel (2003) 110 Cal.App.4th 1122, 11321133, 2 Cal.Rptr.3d 385.)
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