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Case 18-2868, Document 276, 08/09/2019, 2628224, Page35 of 77 criminal prosecutions of (and civil lawsuits against) wealthy and prominent men around the world—to draw an obvious inference that plaintiff was (more) truthful in the 2011 articles and engaged in massive manufacturing of fiction in the 2014 joinder motion. There is no limit to the subject matters on which pure opinions may be expressed with constitutional immunity, including whether a person believes another is “lying” or is a “liar.” See, e.g., Indep. Living Aids, Inc. v. Maxi-Aids, Inc., 981 F. Supp. 124, 128 (E.D.N.Y. 1997) (granting summary judgment: “Read in the context of the entire article, Zaretsky’s remarks, calling Sandler and others ‘liars,’ can only be understood as a denial of their accusations. . . . Even the most careless reader must have perceived that the words were no more than rhetorical hyperbole, a vigorous epithet used by Zaretsky who considered himself unfairly treated and sought to bring what he alleged were the true facts to the readers. The epithet ‘liar’ in this context, standing by itself, merely expressed the opinion that anyone who persisted in accusing Zaretsky of improper business practices could not be telling the truth. Since the basis for this opinion was fully set forth, the communication of Zaretsky’s views cannot be libelous.”) (citations, ellipsis, brackets and internal quotations omitted); see Gross v. New York Times, 623 N.E.2d 1163, 1169 (N.Y. 1993) (“[E]ven when uttered or published ina... serious tone, accusations of criminality could be regarded as mere hypothesis and therefore not actionable if the facts on which they are based are fully and accurately set forth and it is clear to the reasonable reader . . . that the accusation is merely a personal surmise built upon those facts. In all cases, whether the challenged remark concerns criminality or some other defamatory category, the courts are obliged to consider the communication as a whole, as well as its immediate and broader social contexts, to determine whether the reasonable listener . . . is likely to understand the remark as an assertion of provable fact.”’). 28