c. News

While the Second Circuit does require that information be gathered in the newsgathering process to be covered by the reporter's privilege, it has not specifically defined the term "news." Yet the Second Circuit in Von Bulow v. Von Bulow made it clear that newsgathering only includes efforts to disseminate information to the public. 811 F.2d 136, 145 (2d Cir. 1987); see also infra Section IV.A.2. Examples of newsgathering include a journalist's discussions with a confidential source that the journalist intends to publish in a newspaper, United States v. Aponte-Vega, 20 Med. L. Rep. 2202 (S.D.N.Y. May 29, 1992); a network's filming of traffic stops by a policeman for the purpose of broadcasting the stops on a television show, Gonzales v. National Broadcasting Co., 194 F.3d 29 (2d Cir. 1999); and a financial newsletter's acquisition of a tape recording of a conference call which contained information about a conspiracy that the newsletter intended to publish, PPM America, Inc. v. Marriott Corp., 152 F.R.D. 32 (S.D.N.Y. 1993).