In order to win the defamation case, Smartmatic will need to prove that the defendants spread the lies with "actual malice," meaning that they either knowingly spread misinformation or recklessly disregarded the truth. Although Murdoch's name is missing from the list of defendants, proving that he was personally involved in the decisions that shaped Fox's coverage while serving as chairman of the company could help Smartmatic prove that Fox Corp is liable. The 92-year-old retired from his perch as king of his media empire—which encompasses Fox, The Wall Street Journal, The New York Post, and the Dow Jones Newswire, among others—in September, turning the management of the company over to his son, Lachlan Murdoch.