California, United States of America
The following excerpt is from Gomes v. Fried, 136 Cal.App.3d 924, 186 Cal.Rptr. 605 (Cal. App. 1982):
Where, as here, the defamatory language is not libelous on its face, unless the plaintiff proves special damage as defined by section 48a, no cause of action arises. (Forsher v. Bugliosi (1980) 26 Cal.3d 792, 807, 163 Cal.Rptr. 628, 608 P.2d 716.)
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