in a manner which amounted at least to negligence on the part of the defendant; and caused damages to the plaintiff. Additionally, American courts apply special rules in the case of statements made in the press concerning public figures, which can be used as a defence. While plaintiff alleging defamation in an American court must usually prove that the statement caused harm, and was made without adequate research into the truthfulness of the statement; where the plaintiff is a celebrity or public official, they must additionally prove that the statement was made with actual malice (i.e. the intent to do harm or with reckless disregard for the truth). A series of court rulings led by New York Times Co. v. Sullivan, 376 U.S. 254 (1964) established that for a public official (or other legitimate public figure) to win a libel case in an American court, the statement must have been published knowing it to be false or with reckless disregard to its truth (i.e. actual malice). The Associated Press estimates that 95% of libel cases involving news stories do not arise from high-profile news stories, but "run of the mill" local stories like news coverage of local criminal investigations or trials, or business profiles. Media liability insurance is available to newspapers to cover potential damage awards from libel lawsuits. An early example of libel is the case of John Peter Zenger in 1735. Zenger was hired to publish the New York Weekly Journal. When he printed another man's article criticising William Cosby, the royal governor of Colonial New York, Zenger was accused of seditious libel. The verdict was returned as not guilty on the charge of seditious libel, because it was proven that all the statements Zenger had published about Cosby had been true, so there was not an issue of defamation. Another example of libel is the case of New York Times Co. v. Sullivan (1964). The American Supreme Court overruled a state court in Alabama that had found The New York Times guilty of libel for printing an advertisement that criticised Alabama officials for mistreating student civil rights activists. Even though some of what The Times printed was false, the court ruled in its favour, saying that libel of a public official requires proof of actual malice, which was defined as a "knowing or reckless disregard for the truth". Many jurisdictions within the Commonwealth (e.g. Singapore, Ontario, and