In the months leading up to the 2016 election, Christopher Steele, a former British intelligence agent, was hired by a Washington, D.C., research firm to investigate whether then-candidate Donald Trump had any ties to Russia and Vladimir Putin. While Steele’s report was relatively inconclusive on Trump, it did report on the dealings of three Russian businessmen: German Khan, Mikhal Fridman, and Petr Aven. Steele’s report alleged that the businessmen advise Putin on foreign policy, especially concerning the United States, and that they used their connections to “deliver large amounts of illicit cash to the Russian president [Putin]” in the 1990s. The trio sued Steele’s firm for defamation, and Steele moved to dismiss, arguing his words were protected by First Amendment. Is Steele’s report protected by the First Amendment, despite Steele not being an American citizen? How do you think the court ruled on the First Amendment and defamation issues?