Cantrell v. Forest City Publishing US Supreme Ct. Applied Hill Standard. GM was interviewing Nader's friends and trying to find private facts relating to hookers to discredit Nader. Interviews with acquaintances are not the same as wiretapping and surveillance. Nader required intent but not all jx require intent.
Injunctive relief is more proper.
Relief must be narrowly tailored so as not to spill over onto legitimate photographers who want to cover Jackie O., who is newsworthy.