Conrad and Lady Black: Dancing on the Edge in 2012, the case was described as a "$2.5-million suit" and Bower said, "How can a convicted fraudster find a jury who will say that his reputation has been damaged by a book that says he's a fraudster?" A passing reference in the book to the British businessman, pornographer, and publisher Richard Desmond led to Desmond unsuccessfully suing Bower for libel in 2009. Desmond argued that the description in the book that he was "ground into the dust" when he had published an apology after Black had threatened to sue for libel had weakened his reputation. Notes References Conrad and
Libel tourism made a defense. The Free Speech Protection Act of 2008 and 2009 were both bills aimed at addressing libel tourism by barring U.S. courts from enforcing libel judgments issued in foreign courts against U.S. residents, if the speech would not be libelous under American law. These protections were passed in the 2010 SPEECH Act which passed unanimously in both the House of Representatives and the Senate before being signed by US President Barack Obama on August 10, 2010. In late December 2007, the Second Circuit Court of Appeals, based on a decision by the New York State Court of Appeals,