McKeel v. . Latham

Without regard to the character of the language used on the post card in question, whether libelous or other, it would seem that the allegation of publication is not sufficient to state a cause of action. McIntosh N. C. Practice and Procedure, 362; Annotation, 24 A. L. R., 237.

Under the general rule that a libel is published when, and only when, it is communicated to some third person, who understands it, it has been held in cases dealing with post cards sent through the mails, that, in order to constitute actionable publication, the post card must have been read or communicated to some…