Question: Answer in two or three sentences: What additional two elements must a plaintiff in a libel case prove under the Times v . Sullivan ruling?

Answer in two or three sentences:
What additional two elements must a plaintiff in a libel case prove under the Times v. Sullivan ruling? What is a potential drawback of Times v. Sullivan - in other words, how do critics say it can contribute to shoddy journalism?
Answer in two or three sentences: What additional two elements must

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