alleging the tort of false light needs to plead and prove special damages. Our supreme court has noted that false light is "closely allied" with a defamation action and that "the same considerations apply" to both claims. Jacob v. Bezzant 2009 UT 37, ¶ 21, 212 P.3d 535 (citation and internal quotation marks omitted). However, the supreme court has not explicitly addressed whether a requirement to plead special damages is one of the "same considerations" in a defamation claim that applies to false light. Looking to other jurisdictions, we find that some states appear to require special damages to be pleaded as an element of a false light claim, while others do not. Compare, e.g., Fellows v. National Enquirer, Inc., 42 Cal.3d 234, 228 Cal. Rptr. 215, 721 P.2d 97, 105-09 (1986) (in bank) (<HOLDING>), and Schaffer v. Zekman, 196 Ill.App.3d 727,
holding that a claim for falselight invasion of privacy  requires the pleading of special damages holding that false arrest and false imprisonment claim were not duplicative holding that the offense requires that the return be false as to a material matter holding that a false light claim requires pleading and proof of special damages holding that fraud claim requires proof that the defendant made a material representation that was false