<Li> That the charge must be articulated to a third person, verbally or in writing; </Li> <Li> That the words are not subject to legal protection, such as those uttered in Congress; and </Li> <Li> That the charge must be motivated by malice . </Li> <P> An action of libel required the same five general points as slander, except that it specifically involved the publication of defamatory statements . For certain criminal charges of libel, such as seditious libel, the truth or falsity of the statements was immaterial, as such laws were intended to maintain public support of the government and true statements could damage this support even more than false ones . Instead, libel placed specific emphasis on the result of the publication . Libelous publications tended to "degrade and injure another person" or "bring him into contempt, hatred or ridicule". </P>

What caused the first amendment to be made