Defendant had a picture of plaintiff actress on display at the entrance to his burlesque theater. Plaintiff was not employed by the defendant and was not performing there. Held, that the publication could be found to have been made of and concerning the plaintiff even if the defendant knew nothing about the plaintiff. Louka v. Park Entertainments, Inc., (Mass. 1936) 1 N. E. (2d) 41.
Michigan Law Review,
LIBEL AND SLANDER - "OF AND CONCERNING PLAINTIFF'' - DEFENDANT'S INTENT,
Mich. L. Rev.
Available at: https://repository.law.umich.edu/mlr/vol35/iss2/19