This is a term of art, defined in the relevant statute: https://www.law.cornell.edu/uscode/text/28/4104 https://www.law.cornell.edu/uscode/text/28/4104 > Any U

This is a term of art, defined in the relevant statute: https://www.law.cornell.edu/uscode/text/28/4104 https://www.law.cornell.edu/uscode/text/28/4104 > Any United States person against whom a foreign judgment is entered on the basis of the content of any writing, utterance, or other speech by that person that has been published, may bring an action in district court, under section 2201(a), for a declaration that the foreign judgment is repugnant to the Constitution or laws of the United States.