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Description:Background[ edit ] Hustler's parody, depicted above, includes the unauthorized use of a publicity photograph of Falwell and a near-exact duplicate of the typesetting used in a concurrent Campari advertising campaign. But not in the outhouse. Between mom and the shit, the flies were too much to bear. A jury found in favor of Flynt on the libel claim, stating that the parody could not "reasonably be understood as describing actual facts about [Falwell] or actual events in which [he] participated. Sullivan , U. The New York Times standard focused too heavily on the truth of the statement at issue; for the Fourth Circuit, it was enough that Virginia law required the defendant to act intentionally.

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