(Internal quotation marks omitted.) Gambardella v. Apple Health Care, Inc., 291 Conn. 620, 627–28, 969 A.2d 736 (2009). “Defamation is comprised of the torts of libel and slander: slander is oral defamation and libel is written defamation.”

"A defendant may shield [herself] from liability for defamation by asserting the defense that the communication is protected by a qualified privilege." Gambardella v. Apple Health Care, Inc. , 291 Conn. 620, 628, 969 A.2d 736 (2009) (citation omitted). "When considering whether a qualified privilege protects a defendant in a defamation case, the court must resolve two inquiries.

The malice element "requires a showing that a statement was made with knowledge that it was false or with reckless disregard for its truth." Dowling, 345 Conn. at 165, 282 A.3d 1201 (quoting Gambardella v. Apple Health Care, Inc., 291 Conn. 620, 637, 969 A.2d 736 (2009)). "A negligent misstatement of fact will not suffice; the evidence must demonstrate a purposeful avoidance of the truth."

.'” Skakel v. Grace, 5 F.Supp.3d 199, 206 (D. Conn. 2014) (quoting Gambardella v. Apple Health Care, Inc., 969 A.2d 736, 742 (Conn. 2009)). “To establish a prima facie case of defamation, the plaintiff must demonstrate that: (1) the defendant published a defamatory statement; (2) the defamatory statement identified the plaintiff to a third person; (3) the defamatory statement was published to a third person; and (4) the plaintiff's reputation suffered injury as a result of the statement.” Cweklinsky v. Mobil Chem. Co., 837 A.2d 759, 763-64 (Conn. 2004) (citing QSP, Inc. v. Aetna Casualty & Surety Co., 773 A.2d 906, 916 (Conn. 2001)).

Under Connecticut law, “[a] defamatory statement is defined as a communication that tends to harm the reputation of another as to lower him in the estimation of the community or to deter third persons from associating or dealing with him.” Gambardella v. Apple Health Care, Inc., 291 Conn. 620, 627, 969 A.2d 736 (Conn.2009). “To establish a prima facie case of defamation, the plaintiff must demonstrate that: (1) the defendant published a defamatory statement; (2) the defamatory statement identified the plaintiff to a third person; (3) the defamatory statement was published to a third person; and (4) the plaintiff's reputation suffered injury as a result of the statement.”

(Internal quotation marks omitted.) Gambardella v. Apple Health Care, Inc., 291 Conn. 620, 627–28, 969 A.2d 736 (2009). “A defendant may shield himself from liability for defamation by asserting the defense that the communication is protected by a qualified privilege.... When considering whether a qualified privilege protects a defendant in a defamation case, the court must resolve two inquiries.... The first is whether the privilege applies, which is a question of law over which our review is plenary.... The second is whether the applicable privilege nevertheless has been defeated through its abuse, which is a question of fact.... In a defamation case brought by an individual who is not a public figure, the factual findings underpinning a trial court's decision will be disturbed only when those findings are clearly erroneous, such that there is no evidence in the record to support them.” (Citations omitted.)

Skakel v. Grace, 5 F. Supp. 3d 199, 206 (D. Conn. 2014). "At common law, to establish a prima facie case of defamation, the plaintiff must demonstrate that: (1) the defendant published a defamatory statement; (2) the defamatory statement identified the plaintiff to a third person; (3) the defamatory statement was published to a third person; and (4) the plaintiff's reputation suffered injury as a result of the statement." Gleason v. Smolinski, 319 Conn. 394, 430, 125 A.3d 920 (2015) (quoting Gambardella v. Apple Health Care, Inc., 291 Conn. 620, 627-28, 969 A.2d 736 (2009)). "A defamatory statement is defined as a communication that tends to harm the reputation of another as to lower him in the estimation of the community or to deter third persons from associating or dealing with him."

"A defendant may shield himself from liability for defamation by asserting the defense that the communication is protected by a qualified privilege." Gambardella v. Apple Health Care, Inc. , 291 Conn. 620, 628, 969 A.2d 736 (Conn. 2009). Once a defendant claims that privilege, courts must determine (1) whether or not the privilege applies, which is a question of law, id. at 628, 969 A.2d 736 (citing Miron v. Univ. of New Haven Police Dep't , 284 Conn. 35, 43, 931 A.2d 847 (2007)) ; and (2) if so, whether it has been abused, which is a question of fact, id. at 628, 969 A.2d 736 (citing Bleich v. Ortiz , 196 Conn. 498, 501, 493 A.2d 236 (1985) ). Inline argues that Mr. Kleftogiannis fails to state a claim because the statements made by employees as part of the internal investigation, and included in the report of that investigation, were protected by the intra-corporate communications privilege.

Connecticut law defines "[a] defamatory statement . . . as a communication that tends to harm the reputation of another as to lower him in the estimation of the community or to deter third persons from associating or dealing with him." Skakel v. Grace, 5 F. Supp. 3d 199, 206 (D. Conn. 2014) (quoting Gambardella v. Apple Health Care, Inc., 291 Conn. 620, 627 (2009)). A claim of defamation is comprised of four elements.

Certain types of communications are subject to a qualified privilege, which serves to shield a defendant from liability for defamation. See Gambardella v. Apple Health Care, Inc., 291 Conn. 620, 628 (2009). As the Connecticut Supreme Court has explained: