Paparazzi are freelance photographers known for their relentless pursuit of photographs of famous persons. In Galella v. Onassis (2d Cir. 1973) a federal appeals court defined paparazzo as “literally a kind of annoying insect, perhaps roughly equivalent to the English ‘gadfly.’” The intrusive newsgathering activities of paparazzi have led to cries of invasion of privacy by celebrities, and legislation has been designed to control their activities. Such legislation represents a collision between individual privacy rights and First Amendment free press rights. Perhaps the most famous paparazzo was Ronald Galella, best known for his pursuit of Jackie Onassis and her children. In 1973, the Second Circuit modified but upheld an injunction against Galella, who went to ridiculous lengths to obtain close photographs of the former first lady. The appeals court in Galella reasoned that “Galella’s action went far beyond the reasonable bounds of news gathering.” In 1997 international outrage…