Chau v. Lewis
United States Court of Appeals for the Second Circuit
771 F.3d 118 (2014)
Michael Lewis's book The Big Short described a dinner where Steven Eisman sat next to Wing Chau (plaintiff), founder of Harding Advisory LLC, a top CDO manager. The book described Chau as a fool and “the pilot of the ship of doom,” and said he passed risk onto investors by selling all his CDO interests and prioritizing volume over quality. Chau and Harding Advisory sued Lewis, Eisman, and publisher W.W. Norton (defendants) for libel; the trial court granted summary judgment to the defendants, and Chau appealed.
Whether a written statement must be defamatory, factual, and specifically about the plaintiff, rather than merely opinion or a general statement about a group, to support a libel claim.