Andrew Greene sued Paramount Pictures for defamation arising out of the film “The Wolf of Wall Street.” Although the film did not use his name, Greene alleged that the fictitious toupee=wearing character Nicky “Rugrat” Kosksoff was based on him The film portrayed Rugrat as a “criminal, drug user, degenerate, depraved, and devoid of any morality or ethics.” What would Greene need to prove to be successful in his claim?