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Kramer's financial contributions and public endorsements of gubernatorial candidate Rivera make him a limited public figure for California's election. The debate surrounding Rivera and the nature of Kramer's participation make defamatory statements about his sexuality, business, and contributions relevant to his limited public role. However, Kramer is unable to show COL's statements were published with actual malice, and therefore can not show they breached their required standard of care. Therefore, even though Kramer can show COL's statements meet statutory requirements, his inability to show actual malice is fatal to his libel claim...
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