In other cases, however, the formal structure of common law intentional torts does appear to produce different implications from the structure of the general clauses in the civil codes. Take the tort of defamation. Suppose that a defendant engages in the following behavior, and thereby negligently causes reputational injury to the plaintiff: The defendant makes a certain true communication regarding the plaintiff’s wife to X, which foreseeably leads X to form a belief in a different proposition and communicate that proposition to Y, on which basis Y foreseeably forms the belief that the plaintiff is a serial killer and communicates this belief to Z. Because the tort of defamation affords redress only where a defendant’s communication is “of and concerning” the plaintiff,242 the plaintiff will have no redress for this “reputational injury.”243 Without such a communication, injuring the plaintiff’s reputation by initiating a chain of foreseeable inferences does not engage the terms of the defamation tort. Similarly, suppose that a defendant negligently and foreseeably causes another person to intentionally confine the plaintiff. Since a defendant can commit the tort of false imprisonment only by intentionally confining the plaintiff,244 here the plaintiff will have no false imprisonment claim against the defendant for negligently and foreseeably depriving him of his liberty (or any consequential economic loss).245
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By early 2019, the channels Epstein had spent a decade building around Gates converged into a single pressure campaign.