> Instead, this is a case where the trial of ideas plays out in the pages of peer

> reviewed journals, and the scientific public sits as the jury.” (cleaned up)); Underwager v. Salter,

> 22 F.3d 730, 736 (7th Cir. 1994) (affirming summary judgment against defamation claims and

> stating that “[s]cientific controversies must be settled by the methods of science rather than by

> the methods of litigation”).

So, https://casetext.com/case/underwager-v-salter