On April 19, 2022, the First Department issued a decision in Gardner v. Virtuoso Ltd, 2022 NY Slip Op. 02508, dismissing a defamation claim, explaining:
To the extent the defamation and trade and product disparagement claims are predicated on the 24 alleged directed statements, they should be dismissed because they do not set forth the exact words complained of.
(Internal quotations and citations omitted) (emphasis added).