"Gertz v. Robert Welch, Inc. ... was a case in which the Supreme Court of the United States established the standard of First Amendment protection against defam

"Gertz v. Robert Welch, Inc. ... was a case in which the Supreme Court of the United States established the standard of First Amendment protection against defamation claims brought by private individuals." - https://en.wikipedia.org/wiki/Gertz_v._Robert_Welch,_Inc https://en.wikipedia.org/wiki/Gertz_v._Robert_Welch,_Inc. Ayyadurai would likely be a "limited public figure", under the Gertz v. Welch standard, given his public promotion of himself as the "inventor of email."