Is there any cause of action? Can any joke be used asa cause of action? Are there any damages, i.e. people were compaling to him that he was a revisionist. If no one is criticizing him for the views Coulter attributed to him, isn't it hard to argue people took it seriously?
wouldn't this fall under the Reasonable Person test? Would anyone really assume from Coulter's comments that Rall is actually a Holocaust Revisionist?
Ann Coulter's comment is not actionable. It is not a statement intended to convey a fact, it was clearly a joke and intended as such. A lawsuit by Rall would lead to a fun deposition of Rall, if he were stupid enough to take it that far. One discussion with a lawyer will convince him not to, however. It was an idle threat.