Libel pro quod requires damages because it is not per se.

• A. True
• B. False
• C. It requires extrinsic evidence
• D. It applies only in NY

Answer: (A)

Libel per quod is defamation that isn’t obviously defamatory on its face, so damages aren’t presumed. Because it isn’t per se, the plaintiff must prove actual damages to recover. That’s why this statement is true: libel pro quod requires damages since it is not per se.

In practice, the plaintiff shows harm through evidence of actual injury or economic loss tied to the statement. Extrinsic facts may help establish how the statement was understood and what harm it caused, but the essential point is proving actual damages, not automatic damages. This rule isn’t limited to New York; it’s a general principle.