It has long been settled that what is defamatory — that is, actionable without allegation or proof of special damage — when written may be held not actionable per se if spoken. (See Hartmann v. Winchell, 296 N.Y. 296, 298; Kleeberg v. Sipser, 265 N.Y. 87, 91; Moore v. Francis, 121 N.Y. 199, 204; Kinney v. Nash, 3 N.Y. 177, 178; Oakley v. Farrington, 1 Johns...
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