The Court, in Biro v. Conde Nast held that a defamation claim made by a limited purpose public figure, the plaintiff must plead sufficient facts to demonstrate that the required allegation of actual malice is plausible. In this case, the Second Circuit, in affirming the decision of the District Court, held that the plaintiff had not made any adequate showing of plausibility with respect to actual malice.
The decision in this case can be found here.