In the "Private Facts" Cases of Sidis V

In the "private facts" cases of Sidis v. F-R Publishing, Virgil v. Sports Illustrated, Sipple v. Chronicle Publishing, and Howard v. Des Moines Register, all three plaintiffs lost their appeals for which of the following reasons?

A) reporting someone's criminal record is not considered grounds for a "private facts" case
B) the information for the news story was collected but never published or broadcast
C) the states in which the cases took place had no laws dealing with "private facts" cases
D) the defendants were able to use customary private facts defenses such as newsworthiness, public domain, or consent
E) all of the above