In Steinhilber v Alphonse, 68 N.Y.2d 283 [1986] the Court of Appeals reviewed purportedly defamatory lan-guage used during the course of a labor dispute and affirmed the lower court's dismissal of the lawsuit. The Court noted that the use of exaggerated rhetoric in labor disputes was commonplace and observed that "even apparent statements of fact may assume the character of statements of opinion, and thus be privi-leged, when made in public debate, heated labor dispute, or other circumstances in which an 'audience may anticipate the use of epithets, fiery rhetoric, or hyperbole'" (Steinhilber, 68 N.Y.2d at 294). Clearly, when viewed in the context in which it was introduced, the subject written resolution is nothing more than the manifestation of a point of view expressed within the (acknowledged) context of a contentious labor dispute involving the reassignment of a recalcitrant teacher to another school. A statement such as "Principal from Hell" or "Satan" is nothing more than exaggerated hyperbole, and statements imputing the plaintiff's use of "prevarication and intimidation against staff," "launching an attack on the leadership of the UFT," and engaging "in harassment and assault on the union and its members" would be understood, by the likely readers of the resolution (member teachers of the union who were un-doubtedly aware of the often contentious relationships between chapter leaders and school principals), as such (id.). The Court of Appeals further noted that: "The rule ... may be simply stated. An expression of pure opinion is not actionable. It receives the Federal constitutional protection accorded to the expression of ideas, no matter how vituperative or unreasonable it may be. A "pure opinion" is a statement of opinion which is accompanied by a recitation of the facts upon which it is based. An opinion not accompanied by such a factual recitation may, nevertheless, be "pure opinion" if it does not imply that it is based upon undisclosed facts. When, however, the statement of opinion implies that it is based upon facts which justify the opinion but are unknown to those reading or hearing it, it is a "mixed opinion" and is actionable. The actionable element of a "mixed opinion" is not the false opinion itself- it is the implication that the speaker knows certain facts, unknown to his audience, which support his opinion and are detrimental to the person about whom he is speaking."