A statement is made with "actual malice" if it is made "with knowledge that it [is] false or with reckless disregard of whether it [is] false or not."

Our country has a "profound national commitment to the principle that debate on public issues should be uninhibited, robust, and wide-open, and that it may well include vehement, caustic, and sometimes unpleasantly sharp attacks on government and public officials."

Indeed, the Court has long held that "erroneous statement is inevitable in free debate, and... it must be protected if the freedoms of expression are to have the `breathing space'that they `need... to survive.'"

On a variety of levels, unregulated corporate electioneering might diminish the ability of citizens to "hold officials accountable to the people," ante, at 898, and disserve the goal of a public debate that is "uninhibited, robust, and wide-open,"

—stating that the attack on the validity of the Sedition Act of 1798 "has carried the day in the court of history

Finally, "[t] he right to criticize public officials is at the heart of the First Amendment's right of free speech."

The Second Circuit has recognized that "[f] alse speech, as well as hyperbole, is still entitled to First Amendment protection, as long as it is not made with knowledge or reckless disregard of its falsity."

It is undisputed that the actual malice standard for defamation applies because Plaintiffs are public figures.