For instance, in Wilbanks v. Wolk, 121 Cal.App.4th 883, 17 Cal.Rptr.3d 497 (Ct.App.2004), Gloria Wolk, a consumer advocate and expert on viatical settlements (arrangements in which dying persons sell their life insurance policies to investors to help pay for medical care and other expenses), posted negative comments on her website about a certain broker of such settlements.