Law.com has an article about how a federal jury in Pennsylvania found that the New York Times had defamed a pharmaceutical business--but there were no damages.
In a quirky conclusion to a libel suit against The New York Times, a federal jury Monday found that the newspaper had defamed a Philadelphia business and had done so "intentionally, recklessly or negligently," but that the plaintiff was entitled to no money since it had not suffered any "actual harm." . . .
In the suit, plaintiff Franklin Prescriptions Inc. in Philadelphia claimed it was the victim of "defamation by implication" when The Times used a portion of Franklin's Internet site as a graphic to illustrate an Oct. 25, 2000, article headlined "A Web Bazaar Turns Into a Pharmaceutical Free-for-All." . . .
The most damaging aspect of the article, Bochetto said, was a list of "safety tips," published just to the right of the Franklin graphic, that warned readers to avoid Internet sites of pharmaceutical companies that do not list a phone number or address.
I guess the verdict makes sense: the graphic by the text could have made a defamatory implication, but the only people who would read and incorporate that implication would be people who would not have bought from Franklin anyway, so there were no damages.