I'm not American, and we're discussing a UK news story.

But I genuinely didn't know that other countries do things differently. What does defamation even mean if it doesn't include the concept of untruth?

Previously, [1] https://news.ycombinator.com/item?id=40682485 (obviously, it means different things to different folks; I can't properly answer your question)

FWIW I'm only really familiar with the American usual.