In Palm Springs Tennis Club v. Rangel (1999) 73 Cal.App.4th 1, the defendant falsely asserted in campaign literature that the corporate minutes of the board reflected that the board's chairperson assaulted her. The club sued for libel. The court held it had no right of action: "Words written about a corporate officer give no right of action to the corporation unless spoken or written in direct relation to the trade or business of the corporation. " ( Id. at p. 6.)