or defamation-type harm. See Baggs v. Eagle-Picher Indus., Inc., 957 F.2d 268, 273 (6th Cir.1992) (acknowledging that a statement is defamatory under Michigan law “if it tends ... to harm the reputation of another”). We thus conclude that, regardless of how Compuware phrases the relief sought, its only injuries are defamation-type harm resulting from Moody’s publication of protected speech, and application of the actual-malice standard to Compuware’s breach of contract claim is appropriate. Cf. Cohen, 501 U.S. at 671, 111 S.Ct. 2513 (finding that a plaintiff who asserted a promissory estoppel claim was not attempting to avoid the actual-malice standard because he was “not seeking damages for injury to his reputation or his state of mind”); Food Lion, 194 F.3d at 522-24 (4th Cir.1999) (<HOLDING>). At base, the lack of a contractual injury
recognizing that where a plaintiff failed to perform because of the defendants breach the plaintiff could recover damages caused by the defendants breach holding that a defamation claim is a personal injury tort claim holding that a plaintiff could not recover defamationtype damages from the defendants publication without satisfying the stricter standards of a defamation claim holding that a plaintiff could recover actual damages under the tcpa for loss of credit if the plaintiff submitted sufficient proof of the amount damages requested holding for defamation per se claims plaintiff is entitled to recover at a minimum nominal damages