Why Are There So Few Convictions of Those Who Sharply

Why are there so few convictions of those who sharply criticize politicians and other public figures for libel?

A) Public figures are rarely the subject of libel.
B) The public figure must prove that the defendant deliberately spread false and malicious information.
C) Newspaper outlets retain high-profile attorneys who are so skilled that the public figures never really have a chance.
D) Determining what transpired in the spoken word is incredibly difficult without audio recordings.
E) Verifying who a voice belongs to in an audio recording is difficult.