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California Civil Code Section 45a

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A libel which is defamatory of the plaintiff without the
necessity of explanatory matter, such as an inducement, innuendo or
other extrinsic fact, is said to be a libel on its face.  Defamatory
language not libelous on its face is not actionable unless the
plaintiff alleges and proves that he has suffered special damage as a
proximate result thereof.  Special damage is defined in Section 48a
of this code.

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Last modified: January 12, 2009