Koutsogiannis v The Random House Group Ltd [2019] EWHC 48 (QB) (18 January 2019)

Koutsogiannis v The Random House Group Ltd [2019] EWHC 48 (QB) (18 January 2019)

The book bears the defamatory factual meaning that the Claimant was involved in a network of collusive behaviour, whereby he, along with many other traders, brokers and bank employees all over the world, deliberately tried to manipulate the Libor rate to the benefit of his own or his employers' trading positions but to the potential detriment of a very large number of people and entities including those who paid more than they should have done for financial products or services linked to the Libor rate. The meaning is factual, not opinion. The book does not allege the Claimant was dishonest or criminal, and any such value judgments are for the reader, not part of the natural and ordinary...

Citation
[2019] EWHC 48
Parties
Claimant: Panagiotis Koutsogiannis; Defendant: The Random House Group Limited
Jurisdiction
England and Wales
Judgment Date
18 January 2019
Procedural Posture
Libel Action / Judgment on Preliminary Issues (meaning and Fact/opinion)
Outcome
Defamatory meaning found as stated; meaning is factual, not opinion; judgment on preliminary issues for Claimant in part and Defendant in part.
Legal Topics
Libel, Meaning of Defamatory Statements, Fact Vs Opinion, Repetition Rule, Chase Levels, Book Publication Context
Defamation Media Law Libel Meaning of Defamatory Statements Fact Vs Opinion Repetition Rule Chase Levels Book Publication Context

Case Brief

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Parties

Panagiotis Koutsogiannis

Claimant

The Random House Group Limited

Defendant

Procedural Posture

Libel Action / Judgment on Preliminary Issues (meaning and Fact/opinion)

Legal Issues

  1. 1 What is the natural and ordinary meaning of the words complained of in the book 'The Spider Network' as they relate to the Claimant?
  2. 2 Are the words complained of, insofar as they refer to the Claimant, statements of fact or opinion?

Ratio Decidendi

The book bears the defamatory factual meaning that the Claimant was involved in a network of collusive behaviour, whereby he, along with many other traders, brokers and bank employees all over the world, deliberately tried to manipulate the Libor rate to the benefit of his own or his employers' trading positions but to the potential detriment of a very large number of people and entities including those who paid more than they should have done for financial products or services linked to the Libor rate. The meaning is factual, not opinion. The book does not allege the Claimant was dishonest or criminal, and any such value judgments are for the reader, not part of the natural and ordinary...

Court Disposition

Defamatory meaning found as stated; meaning is factual, not opinion; judgment on preliminary issues for Claimant in part and Defendant in part.

Orders

  • The natural and ordinary meaning of the words complained of is as set out in the judgment.
  • The meaning is factual, not opinion.