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

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New York Times Co. v. Sullivan held that there must be proof of "actual malice" to find libel against a public figure, meaning that the defendant published a statement with knowledge that it was false or with reckless disregard for whether it was false or not. Property loss, a written record, and actual harm are not necessarily required for a finding of libel against a public figure.