The following excerpt is from Miller v. Sawant, 21-35004 (9th Cir. 2021):
Id. at 291-92; accord Rosenblatt v. Baer, 383 U.S. 75, 80 (1966) ("[I]n the absence of sufficient evidence that the attack focused on the plaintiff, an otherwise impersonal attack on governmental operations cannot be utilized to establish a libel of those administering the operations.").
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