Kapellas v. Kofman
In Kapellas v. Kofman (1969) 1 Cal.3d 20, the court held that " in determining whether a particular incident is 'newsworthy' and thus whether the privilege shields its truthful publication from liability, the courts consider a variety of factors, including the social value of the facts published, the depth of the article's intrusion into ostensibly private affairs, and the extent to which the party voluntarily acceded to a position of public notoriety."
In Kapellas v. Kofman, supra, 1 Cal.3d 20, the Supreme Court noted that cases involving the tort of unwarranted publication of embarrassing private facts fell outside the category of cases for which section 48a contemplated coverage. "Since the complaint does not rest upon the inaccuracy of a statement but upon the unwanted publicity resulting from an article, the private party gains no relief from a subsequent retraction or correction of the article but, on the contrary, suffers additional injury by the repeated exposure." ( Kapellas, supra, 1 Cal.3d at p. 35.)