Limbaugh attempts to walk-back "she's a slut and prostitute" comment...instead digs deeper ditch

[Sparkly]

20. Hmm...

"...a personage of great public interest or familiarity like a government official, politician, celebrity, business leader, movie star, or sports hero."
http://legal-dictionary.thefreedictionary.com/Public+Figure

A person can also become a "limited public figure" by engaging in actions which generate publicity within a narrow area of interest. For example, a woman named Terry Rakolta was offended by the Fox Television show, Married With Children, and wrote letters to the show's advertisers to try to get them to stop their support for the show. As a result of her actions, Ms. Rakolta became the target of jokes in a wide variety of settings. As these jokes remained within the confines of her public conduct, typically making fun of her as being prudish or censorious, they were protected by Ms. Rakolta's status as a "limited public figure".
http://www.expertlaw.com/library/personal_injury/defamation.html

To begin with, a fairly high threshold of public activity is necessary to elevate a person to public figure status... and, as to those who are not pervasively involved in public affairs, they must have "thrust themselves to the forefront of particular public controversies in order to influence the resolution of the issues involved" to be considered a "limited purpose" public figure.
http://www.lectlaw.com/def2/p117.htm

I don't think testifying made her a household name; MAYBE a "limited public figure" but even that seems like a stretch.