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Day Pitney's victory for Yale University in the Second Circuit was featured in the American Lawyer on August 15. The lawsuit, brought by South Korea's Dongguk University, alleged that a Yale administrator had erroneously verified a Dongguk professor's fraudulent Yale Ph.D. and that a Yale spokeswoman erroneously told the Korean media that the verification too was fraudulent. Dongguk brought claims of defamation, negligence, and reckless and wanton conduct and sought to recover more than $50 million in alleged damages. The court held that there was no evidence that Yale had published any statements with actual malice, and no evidence that the erroneous Ph.D. verification had caused Dongguk's alleged damages.