Tom Bower on the grounds of the story being "substantially true". The action was heard in July 2009 and Desmond lost the case. An unauthorised biography by Bower of Richard Desmond, titled "Rough Trader", was written and printed in 2006, but still awaits publication. In 2011 Bower published a biography of the Formula One executive Bernie Ecclestone titled "No Angel: The Secret Life of Bernie Ecclestone." Ecclestone cooperated with Bower in the writing of the book, facilitating introductions to people for Bower. Over lunch Ecclestone told Bower "You write what you like, provided it's more or less the truth, because I'm no
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,