Uhh, are you serious? The article is about a speculation, and even starts with "The simple answer is yes, but it would be complicated. " But the fact that there is no federal libel statute is a fact; Times v Sullivan is taught even in non-law classes; it quotes a senior Fellow at Yale law School; and the Renquist example is hardly a little-known case.

So what on earth could you mean by "has no basis in fact?"