tort concerning privacy that is similar to the tort of defamation. For example, the privacy laws in the United States include a non-public person's right to privacy from publicity which puts them in a false light to the public. A non-public person's right to privacy from publicity is balanced against the First Amendment right of free speech. False light laws are "intended primarily to protect the plaintiff's mental or emotional well-being". If a publication of information is false, then a tort of defamation might have occurred. If that communication is not technically false but is still misleading, then a tort of false light might have occurred. The specific elements of the Tort of false light vary considerably even among those jurisdictions which do recognize this tort. Generally, these elements consist of the following: A publication by the defendant about the plaintiff; Made with actual malice (very similar to that type required by New York Times v. Sullivan in defamation cases); Places the plaintiff in a false light; and Highly offensive (i.e., embarrassing to reasonable persons) Thus in general, the doctrine of false light holds: One who gives publicity to a matter concerning another before the public in a false light is subject to liability to the other for invasion of privacy, if (a) the false light in which the other was placed would be highly offensive to a reasonable person, and (b) the actor had knowledge of or acted in a reckless disregard as to the falsity of the publicized matter and the false light in which the other would be placed. For this wrong, money damages may be recovered from the first person by the other. At first glance, this may appear to be similar to defamation (libel and slander), but the basis for the harm is different, and the remedy is different in two respects. First, unlike libel and slander, no showing of actual harm or damage to the plaintiff is usually required in false light cases, and the court will determine the amount of damages. Second, being a violation of a Constitutional right of privacy, there may be no applicable statute of limitations in some jurisdictions specifying a time limit within which period a claim must be filed. Consequently, although it is infrequently invoked, in some cases false light may be a more attractive cause of action for plaintiffs than libel or slander, because the burden of