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 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,