The rule of New York Times v. Sullivan has been extended to cover litigation where the plaintiff is a public figure. A person may be deemed a “public figure” on one of two grounds: (i) where he has achieved such pervasive fame or notoriety that he becomes a public figure for all purposes and contexts (e.g., celebrity sports figure); or (ii) where he voluntarily assumes a central role in a particular public controversy (e.g., prominent commu-nity activist) and thereby becomes a “public figure” for that limited range of issues. [Gertz v. Robert Welch, Inc., 418 U.S. 323 (1974)]