No. First, that 'pervasively' in the news standard is really, really high. If, for example, you're the attorney representing a celebrity on some murder charge and you've been appearing nightly on five talk shows for a couple of months, you're probably not a public figure. You're a limited public figure. You have to be a celebrity or politician, or a high-power businessman to be a public figure.
So the question is whether she is a limited public figure. Even then, you can't take those shows into account because you're judging it from the time that Limbaugh talked about her, not now. You can't take into about any notoriety she got because of Limbaugh's comments, or any press she got because of Limbaugh's comments, or any shows she's been on since she spoke to the Democrats.
I believe the test is . . . when Limbaugh called her a slut and claimed she said these things about her sex life, was she a limited public figure. The precise moment before Rush first mentioned her, would the American public would have recognized her face or name? If you mentioned "contraception', what percentage of the American public would have had her face or name come to mind?
Is that the test to win such a lawsuit, or just to file one, or both? Thanks.