In Sisler v. Gannett Co., Inc., 104 N.J. 256, 281, 516 A.2d 1083 (1986) the Court upheld a jury's award of $ 200,000 for damage to the plaintiff's reputation from libelous newspaper articles. The Court offered guidelines for assessing a plaintiff's burden of proving such general, as opposed to special (or pecuniary), damages: Injury to reputation, even more so than personal injury or mental anguish, which are both amenable to expert testimony, defies exact measurement. The type of direct testimony lacking here has traditionally been hard to produce; in fact, it was this difficulty that engendered the "presumed damages" doctrine. However, the inherently amorphous quantification of libel damages potentially enables juries to vary damages awards in accordance with the popularity or unpopularity of the speaker or the view expressed. Accordingly, a plaintiff should offer some concrete proof that his reputation has been injured. One form of proof is that an existing relationship has been seriously disrupted, reflecting the idea that a reputation may be valued in terms of relations with others. Testimony of third parties as to a diminished reputation will also suffice to prove "actual injury." Awards based on a plaintiff's testimony alone or on "inferred" damages are unacceptable. Id. at 281, 516 A.2d 1083. Under that standard, the Court found that the plaintiff had presented sufficient evidence that one of his relationships had been "permanently impaired" by the articles. Ibid.