The Second Circuit's test for who can benefit from the reporter's privilege is broad. The Second Circuit, in Von Bulow v. Von Bulow, held that "the individual claiming the privilege must demonstrate, through competent evidence, the intent to use material -- sought, gathered or received -- to disseminate information to the public and that such intent existed at the inception of the newsgathering process." 811 F.2d 136, 144 (2d Cir. 1987). The court went on to say: "The intended manner of dissemination may be by newspaper, magazine, book, public or private broadcast medium, handbill or the like, for 'the press in its historic connotation comprehends every sort of publication which affords a vehicle of information and opinion.'" Id. (quoting Lovell v. Griffin, 303 U.S. 444 (1938).