Early in Trump’s campaign, he tossed out the idea of stricter laws on media reportage on public figures essentially lowering the bar on libel. The idea got a lot of negative comments on this forum as being an attack on free speech and a bad Trump idea. European courts on the other hand take actionable libel seriously and therefore British tabloids and similar make sure they have the story straight about EU politicians before they publish scandalous stories. On this side of the pond, not so much.
One of the criteria is "actual malice." The other is "wanton and willful disregard for veracity." The "Russian whores pissing on each other" story could be considered an example of both, and Trump could very well build a case against any media that published that dreck.