News has a dual character separating its informational substance from its expression.

Evidence

In considering the general question of property in news matter, it is necessary to recognize its dual character, distinguishing between the substance of the information and the particular form or collocation of words in which the writer has communicated it. — Henry M. Hart, Jr. and Albert M. Sacks, The Legal Process, 2017

Categorization

• XREF: connects to: A picture-based libel claim requires pleading the picture’s defamatory character in the complaint — Henry M. Hart, Jr. and Albert M. Sacks, The Legal Process: Basic Problems in…, 1113