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Justice Braun http://nycourts.law.com/CourtDocumentViewer.asp?view=Document&docID=41063 PLAINTIFF, ADVISER to a Harlem library where President Bill Clinton made a campaign appearance, claimed to have been libeled in the novel “Primary Colors,” alleging that she was portrayed as a character who slept with a politician thinly disguised as President Clinton. Summarily dismissing her action, the court held that as a work of fiction, the book should not be held to the same investigative standards as a work of non-fiction. Referring to Springer v. Viking Press, it ruled that to constitute defamation, a fictional character “must be so closely akin to the real person claiming to be defamed that a reader . . . knowing the real person, would have no difficulty linking the two.” Finding no such link, the court held that the similarities between plaintiff and the character “were inadequate for a reader, even one who knows plaintiff, to reasonably believe that the characterization of [the character] in “Primary Colors” was ‘of and concerning’ plaintiff.”

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