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Case 18-2868, Document 276, 08/09/2019, 2628224, Page56 of 77 not it was true.” /d. at 667 (internal quotations omitted). Reckless disregard means the defendant made the false publication “with a high degree of awareness of probable falsity” or “entertained serious doubts as to the truth of [the] publication.” /d. (internal quotations omitted). In a defamation action, a plaintiff will be required to prove actual malice in two different and independent contexts: a defamation action in which the plaintiff is a public figure, and a defamation action in which the defendant asserts the privilege of reply. The defamation plaintiff at trial and in summary judgment proceedings must prove her case by clear and convincing evidence. C. Plaintiff is a public figure who must prove actual malice. Public figures include those who have “thrust themselves to the forefront of particular public controversies in order to influence the resolution of the issues involved. . . . [T]hey invite attention and comment.” Gertz, 418 U.S. at 345. The essential element for a finding that a person is a public figure is that she has “taken an affirmative step to attract public attention,” has “strived to achieve a measure of public acclaim.” James v. Gannett Co., 353 N.E.2d 834, 876 (N.Y. 1976). In New York Times Co. v. Sullivan, 376 U.S. 254 (1964), the United States Supreme Court held that, in cases involving public officials, the interests of an individual are trumped by society's interest in promoting free press discussion of matters of general concern. Biro v. Condé Naste, 963 F. Supp. 2d 255, 269 (S.D.N.Y. 2013). Thus, the Court held that a public official alleging defamation must establish that a falsehood has been published with “actual malice.” Sullivan, 376 U.S. at 279-80; accord, Lerman v. Flynt Dist. Co., Inc., 745 F.3d 123, 136 (2d Cir. 1984); Biro, 963 F. Supp. 2d at 269. Subsequently, the Supreme Court extended this standard to all public figures, Curtis Publ'g Co. v. Butts, 388 U.S. 130 (1967), and decided in Gertz v. Robert Welch, Inc., 418 U.S. 323 (1974), that individuals that “are not public figures for all purposes 49