that require the allegation and proof of additional facts. For example, in
libel or slander, the statement in question may not appear defamatory on its
face (such as “Mr. Smith is a member of a particular club”), so the plaintiff
has to prove additional facts to establish its defamatory nature (“Every member
of that club is a sex offender”). In such actions, the plaintiff has to prove
that he suffered damages in order to have a cause of action.