Guess you did.
"We must decide whether a public figure may recover damages for emotional harm caused by the publication of an ad parody offensive to him, and doubtless gross and repugnant in the eyes of most. Respondent would have us find that a State's interest in protecting public figures from emotional distress is sufficient to deny First Amendment protection to speech that is patently offensive and is intended to inflict emotional injury, even when that speech could not reasonably have been interpreted as stating actual facts about the public figure involved. This we decline to do." Hustler Magazine, Inc. et al. v. Jerry Falwell
Public figures have to prove ACTUAL MALICE. Ted Rall has interjected himself into the public sphere. He will lose. Worse for him, he will make himself into the parody figure that Ann desires most, the whiny, litigious liberal. And Ted will pay by the hour, while Ann may represent herself if it comes to that--though it is far more likely the ACLU will beg her to let them work for her, another dream come true for Ms. Coulter, I would reckon.
I would argue Ted Rall is not a "public figure." Certainly not on the par that Jerry Falwell was in the 1980's.