New York Times Co. v. Sullivan held that there must be proof of which of the following in order to find libel against a public figure?

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New York Times Co. v. Sullivan held that there must be proof of purposeful reporting of an untruth (also known as actual malice) in order to find libel against a public figure. This means that the defendant must have known that the information was false or acted with reckless disregard for the truth. Proof of actual harm or property loss is not necessary for a finding of libel in this context.