R. Cafeteria, Inc. v. Kingsborough Community College of City University of New 14 York, 847 N.Y.S.2d 902 (N.Y. Sup. Ct. Aug. 21, 2007) 21 Kane v. Orange Cnty. Publ in, 232 A.D.2d 526, 527 (2d Dept. 1996) 8 Keohane v. Stewart, 882 P.2d 1293 (Colo. 1994) 17 Kforce, Inc. v. Alden Personnel, Inc., 288 F.Su

rts, recognizes a qualified privilege to respond in self-defense to verbal defamatory attacks levied by another upon the speaker. See, e.g., Kane v. Orange Cnty. Publ'n, 232 A.D.2d 526, 527 (2d Dept. 1996) ("[S]ince the open letter was the [defendant's] response to unfavorable publicity against him—publicit