The First Department affirmed a decision dismissing defamation claims asserted by a co-op shareholder against individual members of the co-op’s board of directors.  The appellate court held that the plaintiff’s failure to allege facts supporting the theory that the statements at issue were defamatory per se – i.e., that the statements tended to injure her in her profession – defeated the claims, as did the plaintiff’s failure to allege special damages.  The underlying motion to dismiss had been successfully litigated by Andy Theodosiou. To view the appellate decision, click here.