California, United States of America
The following excerpt is from Nguyen v. Do, C081158 (Cal. App. 2019):
2. Normally each allegedly defamatory statement gives rise to a separate cause of action, or "count" even if each is based on the same legal theory of libel. (Cf., e.g., Shively v. Bozanich (2003) 31 Cal.4th 1230, 1238 -1239.)
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