In Biondi v. Nassimos, 300 N.J. Super. 148, 154-55, 692 A.2d 103 (App.Div.1997), the defendant rose at a public meeting of the New Jersey Board of Examiners of Master Plumbers and accused the plaintiff, chairman of the Board, of having "mob connections" and planning to "order a hit" on the defendant if he did not stop complaining. The trial court dismissed the plaintiff's slander action on summary judgment, reasoning that the comments did not accuse the plaintiff of a crime and thus were not slander per se, and the plaintiff had conceded that he could not prove any special damages. Id. at 152, 692 A.2d 103. The Court affirmed, id. at 157, 692 A.2d 103, noting that the issue was not whether the comments were "defamatory per se" but whether they were "slander per se." Id. at 152, 692 A.2d 103. The Court explained the difference: We note that confusion is sometimes caused by the fact that the term "per se" is used in connection with two quite distinct concepts in the law of defamation. The term "defamation per se" refers to a statement whose defamatory meaning is so clear on its face that the court is not required to submit the issue to the jury. Lawrence v. Bauer Publ'g & Printing, Ltd., supra, 89 N.J. 451 at 459, 446 A.2d 469 1982. On the other hand, "slander per se," the doctrine involved in this appeal, refers to four categories of slander which are considered so clearly damaging to reputation that a plaintiff may establish a cause of action without presenting any evidence of actual damage to reputation. Ward v. Zelikovsky, supra, 136 N.J. at 540, 643 A.2d 972; see generally, Rodney A. Smolla, Law of Defamation 7.04, 7.062 (1986). Id. at 153 n.2, 692 A.2d 103. Citing various treatises and law review articles, we observed that the slander per se doctrine had been "severely criticized" as allowing compensation when there is no harm. Id. at 154-55, 692 A.2d 103. Those critics recommend that "these archaic common law rules presumed damages and special damages should be replaced by a single uniform rule that a plaintiff must prove actual damage to reputation, either pecuniary or non-pecuniary, to establish any cause of action for defamation." Id. at 154, 692 A.2d 103. The Court concluded that until the Supreme Court formally abrogates slander per se (as some other states had), the "lower courts should invoke the slander per se doctrine only in cases where it clearly applies." Id. at 155-56, 692 A.2d 103. Thus we declined to expand the categories of slander per se to include the statements in that case, which did not specifically accuse the plaintiff of past criminal conduct. Id. at 156-57, 692 A.2d 103.