THE PLAINTIFF'S CASE Publication Disseminated to a 3rd party. Who is the publisher? Identification "Of and concerning" Springer v. Viking Press et al Defamation Ordinary meaning in context Raymen v United States Senior Association Harm to reputation Defamation by implication Falsity Public person --- All cases. Private person -- Matters of public concern. Fault Private person must proveNEGLIGENCE. Public person must prove ACTUAL MALICE.