PORTLAND, Ore. - Reversing a trial court's defamation judgment against a blogger, a Ninth Circuit U.S. Court of Appeals panel on Jan. 17 held that the negligence requirement for defamation lawsuits established by Gertz v. Robert Welch Inc. (418 U.S. 323, 350 ) is "not limited to cases with institutional media defendants," but can also apply to Internet bloggers (Obsidian Finance Group LLC, et al. v. Crystal Cox, No. 12-35238 and 12-35319, 9th Cir.; 2014 U.S. App. LEXIS 948).