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Case 18-2868, Document 287, 08/09/2019, 2628251, Page56 of 76 (quoting Rinaldi v. Viking Penguin, Inc., 420 N.E.2d 377, 382 (N.Y. 1981)). However, New York law assigns liability to individuals for the media’s publication of press releases. New York appellate courts have held that an individual is liable for the media publishing that individual’s defamatory press release. See Levy v. Smith, 132 A.D.3d 961, 962-63 (N.Y. App. Div. 2d Dep’t 2015) (“Generally, [o]ne who makes a defamatory statement is not responsible for its recommunication without his authority or request by another over whom he has no control... . Here, however, . . . the appellant intended and authorized the republication of the allegedly defamatory content of the press releases in the news articles.”); see also RESTATEMENT (SECOND) OF Torts § 576 (1977) (“The publication of a libel or slander is a legal cause of any special harm resulting from its repetition by a third person if . . . the repetition was authorized or intended by the original defamer, or . . . the repetition was reasonably to be expected.”) The facts as set forth above establish that Maxwell approved the Press Release. The Press Release was sent to between six and 30 media representatives by Gow as an employee 56