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Introduction Jeffrey Masson, a psychoanalyst, served as a Projects Director of the Sigmund Freud Archives if he became disillusioned with Freudian psychology. He was then fired after he attempted progressing his own theories (Masson v. New Yorker Magazine, 1991). Janet Malcolm, a writer and contributor to New Yorker Magazine, recorded many interviews with Masson and wrote an article featuring many lengthy quotes about his connection with the Sigmund Freud Archives (Masson v. New Yorker Magazine, 1991). Masson had cautioned New Yorker Magazine's fact checker Nancy Franklin about several inaccuracies, but the article was printed anyway, even though some of those quotations were nowhere to be found on the 40 recorded hours of the interview by Malcolm (Sadler, 2005). In addition to being published in the New Yorker Magazine, a publication publisher who had learned about the allegations of inaccurateness still made a decision to publish the quotes into a book, further damaging Masson's reputation. Masson then decided to bring an action for libel under California Law, saying that six of those quotes were defamatory and were not included in the 40 hours of their recorded interview material (Masson v. New Yorker Magazine, 1991). Jeffry Masson filed a lawsuit for defamation against New Yorker Magazine, asserting that publishing the so called fabrications had hurt his reputation. Defamation is defined as "a false communication that harms another's reputation and subjects him to ridicule and scorn" (Trager, 2010, p. 52). The quotations that Masson was the very upset about were being known as an "intellectual gigolo" and being called "the greatest analyst who ever lived" (Masson v. New Yorker Magazine, 1991). In courtroom Masson was announced a public figure and had to.