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?
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?