In Read v. Carpenter, Del. Super., No. 95C-03-171, Quillen, J. (June 8, 1995), the court explains, " a study of the cases clearly indicates that the Courts of this State do not look with favor upon suits for libel or slander.'" The Court further states that "the scope of liability for slander is not as great as that for libel, and the pleading requirements for slander are more strict." The court establishes five elements that must be pled to form a claim for defamation, which incorporates both libel and slander. Those elements are: "(1) the defamatory character of the communication; (2) publication; (3) that the communication refers to the plaintiff; (4) the third party's understanding of the communication's defamatory character; and (5) injury." Additionally, special damages must be pled in a claim for slander.