THE element of identifiability is easily complied with when the writing in question explicitly names the subject or the person being defamed.
In cases, however, where the person subject of the defamatory words was not named, a libel suit may only prosper "if by intrinsic reference the allusion is apparent or if the publication contains matters of description or reference to facts and circumstances from which others reading the article may know the plaintiff was intended, or if he is pointed out by extraneous circumstances so that persons knowing him could and did understand that he was the person referred to."
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