In Fitzgerald, plaintiff claimed published statements about his purported sale of top secret marine mammal weapons systems to other countries was libelous.
From Al-Haramain Islamic Foundation, Inc. v. Bush, No. 06-271-KI (D. Or. Sept. 7, 2006). “Fitzgerald” refers to Fitzgerald v. Penthouse, 776 F.2d 1236 (4th Cir. 1985), and yes, it does discuss dolphins with frickin sensors attached to their heads.
I had never expected to see the words “top secret marine mammal weapons systems” and “libelous” in the same sentence.