What is the test for defamatory language in a letter to the board of directors of CCNH?

43. The circumstances pertaining in Taylor v. Lamon are significantly different from the circumstances in this case. In Taylor v. Lamon both the plaintiff and defendant were members of the union, were both actively involved in union politics, and there was evidence that union members to whom the Special Appeal was sent were immune to the defamatory effects of harsh language. In the present case, the board of directors of CCNH were not immersed in the union culture and there was no evidence that otherwise defamatory remarks would have no effect upon them. In short, the context in Taylor v. Lamon is much different from the context in which the Board Letter was received.