E-Trade had a commercial created for the 2010 Super Bowl. It shows an E-Trade baby explaining to his cute baby girlfriend that he did not call because he was busy diversifying his portfolio on E-Trade. She asks him, "And that milkaholic Lindsay wasn't over?" Lindsay Lohan has filed a $100 million libel lawsuit against E-Trade.

1. What are the elements of libel?
2. What would Ms. Lohan need to show in order to win her suit?
3. In your opinion, was the lawsuit valid? Please explain your answer.