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Case 18-2868, Document 280, 08/09/2019, 2628232, Page62 of 74 this term . . . Indeed, these are terms unlikely to be used by anyone unfamiliar with this litigation. ... Why, for instance, would it be necessary to push down offending Web pages in the results that the search engines provide for the term victim’s refuse silence sex slave, when this term is likely never used . . .” See McCawley Dec. at Exhibit 25, Kent Report at 10, 33. Defendant cannot argue to the Court that Ms. Giuffre has “successfully” invited public attention to her views through her VRS website while simultaneously filing a Daubert motion that argues that search terms such as “victims refuse silence sex slave” are “likely never used,” thus making the website unsuccessful in inviting public attention. In any event, Defendant has failed to set forth with precision the allegedly undisputed fact — and supporting evidence — she uses to support her argument. Moreover, “[i]t is preferable to reduce the public figure question to a more meaningful context by looking to the nature and extent of an individual’s participation in the particular controversy giving rise to the defamation.” Greenberg v. CBS Inc., 69 A.D.2d 693, 704, 419 N.Y.S.2d 988, 995 (1979) (emphasis added), citing Gertz v. Robert Welch, Inc., 418 U.S. 323, 345, 352, 94S. Ct. 2997, 41 L.Ed.2d 789. The context here is highly significant. Ms. Giuffre never chose to participate in Defendant and Epstein’s underage sex ring, a “controversy” that gave rise to Defendant’s defamation. In arguing that Ms. Giuffre thrust herself into the public spotlight, Defendant conveniently leaves out the fact that it is by her doing that Ms. Giuffre is in this controversy in the first place. No minor child willingly becomes a participant in sexual abuse, and it is perverse for the abuser to argue that her victim deliberately became a subject of public attention when speaking out about that abuse for the purpose of advancing justice and helping other victims. 54