Ton Cremers was the director of security at Amsterdam’s famous Rijksmuseum and the operator of the Museum Security Network (“the Network”) Website. Robert Smith, a handyman working for Ellen Batzel in North Carolina, sent an e-mail to the Network alleging that Batzel was the granddaughter of Heinrich Himmler

(one of Hitler’s henchman) and that she had art that Himmler had stolen. These allegations were completely untrue. Cremers posted Smith’s e-mail on the Network’s Website and sent it to the Network’s subscribers. Cremers exercised some editorial discretion in choosing which e-mails to send to subscribers, generally omitting any that were unrelated to stolen art.

Is Cremers liable to Batzel for the harm that this inaccurate information caused?