Public figures such as sports players and celebrities are loved by the public. As their popularity grows, much attention will be paid to their every move and the number of news articles dealing with them will naturally increase. When the competition for coverage overheated, writing articles to get views by referring to the celebrity s past facts became a bad practice. The act of forced recall of past facts can be divided into three main types. If sports players(or celebrities) report in detail or mentions similar past facts at the time of any social controversy, it will not be easy to accuse them of illegal activities for reasons such as having so-called grounds for illegality or difficulty in proving the purpose of slander(In the case of Type 1 and Type 2 it is not easy to acknowledge the illegality). However, in the case of articles or comments written in the form of so-called forced summons of past facts, it is believed that the responsibility for illegal activities can be sought. Under the Constitution, it shall be deemed illegal based on the secrets of privacy and freedom, personal rights, etc(In the case of type 3, illegality may be easily recognized). For example, at the end of an article dealing with an active sports player, there is no public interest in an article written in the way of attaching a once-in-a-lifetime unsavory event, but it greatly violates the player s personality rights. Unexpected forced summons of past facts should be avoided as it is a false press practice, and among the contents of exclusive contracts signed by public figures such as sports players and entertainers, it could be a problem with whether they violate their duty to maintain dignity.