New York Times v. Sullivan fifty years later

What do you think?  I'm sure everyone would have their preferred wording, but I assume everyone can locate their own view in one of the three options below, so don't get hung up on the precise wording--choose the option closest to your view of the case and its legacy.  (The second and third options got chopped: the second should say "by requiring the plaintiff too prove too much" and the third  should conclude "into public figures who can be defamed with impunity".)

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