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Case 18-2868, Document 276, 08/09/2019, 2628224, Page36 of 77 Mr. Barden’s inference from disclosed facts qualifies as “pure opinion,” Steinhilber, 501 N.E.2d at 552. Accordingly, that Mr. Barden characterized plaintiff's 2014 allegations harshly as “obvious lies” as opposed to “untruths” or some softer term is of no moment. “[U]nder New York law, pure opinion . . . is not actionable because expressions of opinion, as opposed to assertions of fact, are deemed privileged and, no matter how offensive, cannot be the subject of an action for defamation.” Ratajack v. Brewster Fire Dep't, Inc. of the Brewster-SE Joint Fire Dist., 178 F. Supp. 3d 118, 158 (S.D.N.Y. 2016) (internal quotations and ellipsis omitted; brackets altered); accord, e.g., Mann v. Abel, 885 N.E.2d 884, 885-86 (N.Y. 2008). The drawing of such inferences would be constitutionally protected even under the standards of the First Amendment that are less protective of opinion than is Article I, Section 8, of the New York Constitution. See Adelson v. Harris, 973 F. Supp. 2d 467, 490 (S.D.N.Y. 2013) (‘In determining whether a statement constitutes constitutionally protected opinion, courts also look to the specific context of the statement. When looking at a statement’s specific context, of particular importance is the principle that when an author outlines the facts available to him, thus making it clear that the challenged statements represent his own interpretation of those facts and leaving the reader free to draw his own conclusions, those statements are generally protected by the First Amendment.”) (internal quotations and brackets omitted). The application of the four Steinhilber factors confirms that the three phrases and/or clauses plaintiff alleges are defamatory are in fact part of a statement that taken as a whole constitutes nonactionable opinion. The premise of plaintiffs Complaint is that once she is able to identify references in the January 2015 statement to any assertion of fact that potentially is subject to proof, e.g., the truth or falsity of her many dozens of allegations old and new, then she has a viable defamation claim. That ignores the teaching of Steinhilber and Immuno AG. As the 29