In Zhao v. Wong (1996) 48 Cal. App. 4th 1114 55 Cal. Rptr. 2d 909, the plaintiff sued an individual for defamation based on the defendant's statements made privately to a San Jose Mercury newspaper reporter. Not surprisingly, the court concluded that such "private" statements did not occur in a "public forum" within the meaning of section 425.16, subdivision (e)(3). (Zhao, supra, 48 Cal. App. 4th at p. 1131.) Although further discussion on this matter was arguably unnecessary, the court went on to conclude that the San Jose Mercury newspaper (which published the statements) was also not a public forum. (Ibid.) Relying on Lafayette Morehouse, Inc. v. Chronicle Publishing Co. (1995) dicta and expressly applying a "narrow definition" of the statutory phrase, the Zhao court reasoned that a public forum " 'refers typically to those places historically associated with First Amendment activities, such as streets, sidewalks, and parks,' " and has been extended only to other public facilities open for certain limited purposes such as libraries and schools. (Id. at pp. 1126-1127.) The court further relied on Lafayette Morehouse's statements that a private newspaper cannot as a matter of law constitute a public forum because the publisher has ultimate control over the newspaper's message. (Id. at pp. 1126, 1131.) Noting that the phrase "public forum" potentially triggers a more "elastic" definition, the Zhao court expressly declined to adopt this definition and instead adhered to the more "restricted" approach. (Id. at pp. 1125, 1127.)