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Assume a picture of an iPhone and a headline which reads: "Software error leads many phones to explode". Now in the article there is a line below the same image used for the headline which says: "Example picture" and the article itself explains that actually a software error in Samsung phones leads many phones to explode.

Imagine now that this headline is widely circulated in social media, where people would see it, but not necessarily read the full article, thus causing reputation damage to Apple. Would Apple have grounds to sue for libel by implication based on the combination of text and image?

Would it still be libel if the target audience for the product is very niche, compared to the above example? For example cleaning equipment, where company's A cleaning equipment causes a pump to break, but the image of the faulty equipment is from company B? Does the size of a target audience only matter in determining how large the reputation damages are or does it change something substantial in regards to other factors which determine if something is libel?

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