nce that makes it a
matter of reasonable inference that the libelous matter was brought to
the actual knowledge of a third person.

A person who voluntarily engages in the interchange of opprobrious
epithets and mutual vituperation and abuse has been held to license
his antagonist to reply in like manner. "The right to answer a libel
by libel is analogous to the right to defend one's self against an
assault upon his person. The resistance may be carried to a successful
termination, but the means used must be reasonable." Common carriers,
news-vendors, proprietors of circulating libraries and others who are
merely unconscious vehicles for carrying defamation generally escape
liability for its publication.

If the publication of a libel is the result of the joint efforts of
several persons, each is responsible for the wrong done to the
plaintiff. If A writes a libel, and B prints it and C publishes it,
the person wronged may sue all jointly, or either one of them
separately. The publication of the same slander by different persons
is not a joint tort, it is a distinct wrong done by each slanderer.

There are distinctions between libel and slander that must be now
stated. Slander is applied to oral speech or its equivalent, libel to
matters expressed in writing or print, pictures, effigies or other
visible and permanent forms. Libel is a criminal offense as well as a
tort, while the slander of private persons is not a common law crime;
but some forms of slander are crimes by statute. Falsely and
maliciously to charge one with committing a felony or other indictable
offense involving moral turpitude is in some states a crime.
Scandalous matter is not necessary to make a libel. "It is enough if
the defendant induces an ill opinion to be held of the plaintiff, or
to make him contemptible or ridiculous." Says Burdick: "Any censorious
or ridiculing writing, picture or sign made intentionally and without
just cause and excuse is a libel upon its victim. The degree of
censure or ridicule is not material. If the language is such that
others, knowing the circumstances, would reasonably think it
defamatory of the person complaining of and injured by it, then it is
actionable."

In many cases of libels which affect the victim chiefly or solely in
his office or vocation their tendency to cause injury is so clear that
proof may be unnecessary. Thus, to import insanity or incompetency to
a professional man, or that a public officia