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
Criminal libel The common law offences of seditious libel, defamatory libel, and obscene libel were abolished in England and Wales and Northern Ireland on 12 January 2010 when section 73 of the Coroners and Justice Act 2009 came into force, blasphemous libel having already been abolished in England and Wales on 8 July 2008 by the Criminal Justice and Immigration Act 2008. The Racial and Religious Hatred Act 2006 created instead the offence of inciting hatred against a person on the grounds of their race or religion. Samoa's Crimes Act 2013 dropped reference to criminal libel, which had been on the statute