Tom Bower "", an investigation into corruption in English football. Bower's joint biography of Conrad Black and Barbara Amiel "" was published in November 2006. In February 2007, Black filed a libel suit in Toronto against Bower over the contents of the book. The suit was frozen when Black was convicted of fraud and imprisoned. The "Daily Express" proprietor Richard Desmond brought a libel action against Bower over a passing reference in "Dancing on the Edge". Desmond claimed that the book included an account of an incident that weakened his "super-tough" reputation as a businessman and was therefore defamatory. Bower denied libel
Libel tourism and on April 29, 2008 Gov. Paterson signed the bill into law. The Libel Terrorism Protection Act enables New York courts to assert jurisdiction over anyone who obtains a foreign libel judgment against a New York publisher or writer, and to limit enforcement to those judgments that satisfy "the freedom of speech and press protections guaranteed by both the United States and New York Constitutions." In October 2009, California Governor Arnold Schwarzenegger signed into law protections against libel tourism (California's Libel Tourism Act) that took effect January 1, 2010. The Act provides that California courts shall not recognize a foreign-country