Susan Brown was assistant to the Vice President of Student Affairs at Georgetown University. The state had an academic honors program called the Governor's Fellows Program, and one of Brown's duties was to help students apply. The school newspaper, theStudent Herald, published an article describing the university's success at placing students in the Fellows Program. The article included a block quotation in larger print, attributed to Brown. Underneath Brown's name was the phrase, "Director of A** Kissing." Brown sued theStudent Herald, alleging that the vulgar phrase defamed her.

What argument(s) would Brown make in this case? What argument(s) can theStudent Heraldmake?