Participated in an amicus brief (with the Reporters Committee and other amici) filed with the New York Supreme Court Appellate Division in Gottwald v. Sebert. The case involves a defamation lawsuit brought by music producer Dr. Luke against artist Kesha over statements made by Kesha and others in her employ about Kesha’s allegations that Dr. Luke sexually assaulted her and singer Katy Perry. Both parties moved for summary judgment. In denying Kesha’s motion for summary judgment, the trial court held, among other things, that Dr. Luke is not a public figure. The amicus brief supports Kesha’s argument on appeal that the trial court erred when it held that Dr. Luke is not a public figure. The brief argues that Dr. Luke is an all-purpose public figure, a general public figure within a relevant community, or a limited-purpose public figure.