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Patso, in my layman's opinion, meets the criteria of a libel-proof plaintiff.

He doesn't have damages obviously, but he doesn't even have defamation. Leslie hasn't posted any factual statements about him that weren't true...

Yes These get a bit more complicated with public figures and Pat would have an extremely hard time not meeting the bar of limited purpose public...

Not a lawyer but followed the Depp vs. Heard trial via Law Tubers a lot. In that jurisdiction at least, the requirement was for 'actual malice'...