Gifford v. National Enquirer
United States District Court for the Central District of California
1993 WL 767192 (1993)
The National Enquirer (defendant) published an article claiming television personalities Kathie Lee and Frank Gifford (plaintiffs) were a "desperate couple" who used artificial insemination and "sperm spinning" to conceive, calling them "hypocrites" given their public statements against artificial insemination on religious grounds; the Giffords sued for libel, and the Enquirer moved to dismiss.
Whether an action for libel per se requires a plaintiff to prove that the defendant published a clearly false and defamatory written statement about the plaintiff, whereas an action based on libel per quod requires the plaintiff to provide extrinsic evidence imparting a defamatory meaning to the words published and to specifically allege special damages.