She's not. She's not 'pervasively' in the news and public eye, so she's not a public figure under Times v. Sullivan.
The question is whether she's a limited public figure. It's true that she thrust herself into the spotlight on this issue, but was she really a public figure when she ended her presentation? How many people here knew who she was by name when she ended her presentation and before Limbaugh opened his mouth?
Federal law's clear that any of the notoriety she got as a result of Limbaugh's comments can't be used in determining whether she was a limited public figure for purposes of figuring out whether Limbaugh defamed her. You have to look at whether the public generally knew who she was before Limbaugh said anything about her.
I doubt one person out of 1,000 could have identified her, even after she finished speaking. And I mean as "oh, she's the lady who spoke about contraception before Congress" (well, the Democrats in a face proceeding).
She was on some (at least one) MSNBC progressive opinion shows because I saw her there before Rush said any of this. I know I posted a comment here about it at the time. She was playing the 'Boo-hoo-hoo they wont let me testify act' almost weeping about her friend with nthe health problem.
That was after the Religous rights House committee rejected her, but before Pelosi’s women's health committee put her on TV/CSPAN. I watch those shows pretty regularly,
Would that be enough to count?