JUSTICE BYRNE
delivered the opinion of the court:
Plaintiff, Tom Myers, alleges that defendant, Nelson Levy, caused his termination as the varsity football coach at Lake Forest High School (the school). On March 30, 2001, plaintiff filed a three-count amended complaint for “defamation, false light, and tortious interference with prospective economic advantage or business opportunity.” The trial court granted defendant summary judgment on each of the three counts, and plaintiff appeals. We affirm in part, reverse in part, and remand the cause for further proceedings.
FACTS
Plaintiffs amended complaint alleges that he was fired as football coach on January 25, 2001, but continues to serve as a teacher and the head varsity baseball coach at the school. Plaintiff graduated from the school in 1966 and has lived in Lake Forest for 34 years. The complaint recites plaintiffs experience as a college athlete and high school coach. Two of defendant’s sons had participated on plaintiffs football teams and graduated from the school. Defendant’s third son was a student athlete at the school at the time plaintiff was removed as football coach. Plaintiff alleges that defendant’s conduct was motivated by his son’s competition with plaintiffs son for the team’s quarterback position.
Plaintiff alleges that, on October 16, 2000, defendant communicated several written defamatory statements to “others.” The statements were contained in a letter addressed to Dr. Jonathan Lamberson, the school superintendent and principal, and Jill Bruder, the athletic director. Defendant recommended removing plaintiff as head football coach. The amended complaint alleges, and defendant concedes, that the correspondence included the following statements:
“a. [Plaintiff] shows little or no concern for players who are injured.
b. When a player is injured, [plaintiff] rarely, if ever calls and never visits, sends a get well card or in any other way expresses concern.
c. [Plaintiff] lacks true concern for the young men who devote so much of themselves to his program.
d. [Plaintiff] lacks the respect as a coach of virtually all of his players!;] *** they have no confidence in [plaintiff] as a leader or a motivator. Sadly they consider him a joke to be worked around, not with.
e. [Plaintiff] sets a very poor example for his coaches and players.
f. As poor as he is as a coach and leader of coaches, much more distressing is [plaintiffs] abysmal failure to support his players.
g. When the team loses, [plaintiff] and some of his assistants make the kids feel like they did not try hard enough.
h. Such is sad, despicable and inexcusable treatment of the group of boys who play their hearts out and are denied the chance to win by the buffoons that direct the action.
i. [Plaintiff] and his program fail miserably.
j. [Plaintiff sets] a poor example as a teacher, who consistently hired poor quality subordinates.
k. [Plaintiff] cared little or nothing about the well[-]being of his students *** [and] commanded the respect of neither his peers nor his pupils.
l. [Plaintiff] is *** grossly unprepared.
m. [Plaintiff] fails as an educator and a leader.”
On November 8, 2000, defendant sent Lamberson a petition letter calling for plaintiffs dismissal as football coach. The correspondence was accompanied by a list of football parents who purportedly agreed with and signed the letter. The envelope and the bottom of each page of the list were labeled “CONFIDENTIAL TO BE VIEWED BY DR. LAMBERSON ONLY.” Defendant allegedly misrepresented the number of signatures he collected and falsely reported that several parents had signed the petition. The record contains written statements signed by six football parents, including one circuit court judge, in which each confirms that defendant falsely reported that he or she signed the petition. In the November 8, 2000, communication to Lamberson, defendant stated that he had spent three years lobbying Bruder and the former superintendent for plaintiffs removal as football coach. The complaint alleges that defendant’s earlier public praise of plaintiff proves that he was not, in fact, dissatisfied with him.
Bruder recommended, Lamberson authorized, and the school board officially approved plaintiffs removal as head football coach on January 25, 2001. On the next day, the Chicago Sun-Times published two statements attributed to defendant. Defendant stated that “[tjhere has been a consistent unhappiness, widespread discontent, with [plaintiff] as football coach for more than a decade.” Defendant also stated, “I was probably the number one antagonist of an organized effort that involved hundreds of people. The thrust was not ■wins or losses, but rather that the kids don’t respect him.” On February 25, 2001, the Chicago Tribune published a third quotation in which defendant stated, “[yjou’ve had an incompetent coach in place for a decade who used to be a good coach.”
The record contains a letter addressed to a group of Lake Forest eighth-grade student athletes in which defendant praised plaintiff in the fall of 1997. The letter states, “Our community has a great coaching role model in [plaintiff]. [Plaintiff] makes every kid on his team feel good about himself. He is a personal role model for character, kindness, and fairness. His players grow from within, not from being bombarded by constant coaching demands. [Plaintiff] builds teams of self-confident kids who are not afraid to make a mistake. And, almost every year, [plaintiff] takes a bunch of under-sized, slow boys into the state play-offs.” In early 1998, defendant wrote a fiftieth birthday tribute to plaintiff in which defendant again praised plaintiff for his exceptional and compassionate coaching.
The defamation count alleges that defendant’s subsequent derogatory statements “injured [plaintiffs] reputation in the community, were false, were malicious, and made with a reckless disregard for their truth. These statements constitute libel and slander per se, and also caused or contributed to cause [plaintiff] to be removed as head varsity football coach at [the school], a position he dearly loved.” Plaintiff earned an additional $7,500 annual salary at the time he was removed from the coaching position.
The false light invasion of privacy count alleges that defendant’s newspaper quotations “placed [plaintiff] in a false light as same would be considered highly offensive by a reasonable person.” Defendant allegedly had knowledge of the falsity of the statements or acted in reckless disregard as to their truth or falsity and the false light in which plaintiff would be placed upon publication of the statements.
The count for tortious interference with prospective economic advantage alleges that defendant knew of and interfered with plaintiff s economic advantage or business opportunity to continue as head football coach. Defendant’s interference allegedly caused or contributed to cause plaintiffs removal. Each of the three counts included a prayer for $50,000 in compensatory damages and $1 million in punitive damages.
Defendant moved to dismiss the amended complaint, and the trial court denied the motion on November 1, 2001. Following the hearing, the trial court found that plaintiff is a public figure for purposes of the litigation.
Defendant subsequently filed a motion for summary judgment, in which he alleged that plaintiff could never prove that defendant acted with actual malice because 42 football parents provided defendant with statements similar to his own. Defendant argued that plaintiffs claims lack merit because the statements were true and because defendant did not act with reckless disregard as to their truth or falsity. Defendant quoted deposition testimony in which plaintiff acknowledged that defendant sincerely believed that each of the allegedly defamatory statements was true. Defendant’s motion also included the deposition testimony of Bruder and Lamberson. Lamberson testified that the decision to remove plaintiff as head football coach “had nothing to do with parental pressure.” Bruder similarly testified that “the failure to renew [plaintiffs] contract as the head football coach at Lake Forest High School for the year 2001 had absolutely nothing to do with the activities of [defendant].” Bruder stated that plaintiff was removed because summertime scheduling conflicts precluded him from serving as the head coach of both the football and baseball teams. At the hearing on the summary judgment motion, the parties essentially debated the truth of defendant’s statements regarding plaintiffs performance as the head football coach. Plaintiff also argued that the issue of whether defendant acted with actual malice was a jury question that could not be resolved on a summary judgment motion.
The trial court granted defendant summary judgment, concluding that defendant’s statements were privileged because he directed them toward the school, a governmental body. The court further concluded that defendant did not act with actual malice because he sincerely believed the veracity of the statements. Finally, the court emphasized Lamberson’s testimony that defendant’s petition did not influence the decision to remove plaintiff as coach. Plaintiff appeals from the November 1, 2001, finding that he is a public figure and from the November 18, 2002, order granting defendant summary judgment on all three counts.
ANALYSIS
On appeal, plaintiff argues that defendant should not have been granted summary judgment because plaintiff is not a public figure and defendant abused a qualified privilege in working toward the removal of plaintiff as the football coach. Plaintiff contends that an issue of material fact exists that precluded the trial court from granting summary judgment. In all appeals from the entry of summary judgment, we conduct a de novo review of the evidence in the record. Espinoza v. Elgin, Joliet & Eastern Ry. Co., 165 Ill. 2d 107, 113 (1995). Summary judgment is appropriate where the pleadings, affidavits, depositions, and admissions on file, when viewed in the light most favorable to the nonmoving party, show that there is no genuine issue of material fact and that the moving party is entitled to a judgment as a matter of law. 735 ILCS 5/2 — 1005(c) (West 2000); Bier v. Leanna Lakeside Property Ass’n, 305 Ill. App. 3d 45, 50 (1999). “Summary judgment is a drastic means of resolving litigation and should be allowed only when the right of the moving party is clear and free from doubt.” Bier, 305 Ill. App. 3d at 50. “Therefore, where reasonable persons could draw divergent inferences from the undisputed material facts or where there is a dispute as to a material fact, summary judgment should be denied and the issue decided by the trier of fact.” Espinoza, 165 Ill. 2d at 114. If a party moving for summary judgment introduces facts which, if not contradicted, would entitle him to a judgment as a matter of law, the opposing party may not rely on his pleadings alone to raise issues of material fact. Hermes v. Fischer, 226 Ill. App. 3d 820, 824 (1992).
1. Defamation and False Light Invasion of Privacy
A statement is considered defamatory if it tends to cause such harm to the reputation of another that it lowers that person in the eyes of the community or deters third persons from associating with him. Bryson v. News America Publications, Inc., 174 Ill. 2d 77, 87 (1996). “To make out a claim for defamation, the plaintiff must set out sufficient facts to show that the defendants made a false statement concerning him, that there was an unprivileged publication to a third party with fault by the defendant, which caused damage to the plaintiff.” (Emphasis added.) Krasinski v. United Parcel Service, Inc., 124 Ill. 2d 483, 490 (1988). Defamatory statements may be actionable per se or actionable per quod. A publication is defamatory per se if it is so obviously and naturally harmful to the person to whom it refers that a showing of special damages is unnecessary and extrinsic facts are not needed to explain it. Dubinsky v. United Airlines Master Executive Council, 303 Ill. App. 3d 317, 323 (1999). A claim for defamation per quod requires the plaintiff to allege both extrinsic facts to establish that the statement is defamatory and special damages with particularity. Dubinsky, 303 Ill. App. 3d at 323. Plaintiff argues that defendant’s statements were defamatory per se.
Illinois courts have recognized four categories of statements that are considered defamatory per se: (1) words that impute the commission of a crime; (2) words that impute infection with a loathsome communicable disease; (3) words that impute an inability to perform or a want of integrity in the discharge of duties of office or employment; or (4) words that prejudice a party, or impute lack of ability, in his or her trade, profession, or business. Dubinsky, 303 Ill. App. 3d at 323. Defendant does not dispute that his statements fall under the third and fourth categories of statements that are defamatory per se; however, he contends that they were conditionally privileged.
In Kuwik v. Starmark Star Marketing & Administration, Inc., 156 Ill. 2d 16, 27 (1993), our supreme court adopted the Restatement (Second) of Torts approach to determine whether a qualified privilege applies in a given defamation case. Gist v. Macon County Sheriffs Department, 284 Ill. App. 3d 367, 372 (1996), citing Restatement (Second) of Torts §§ 593 through 599 (1977). The three types of situations in which a conditional privilege exists are (1) situations that involve some interest of the person who publishes the defamatory matter; (2) situations that involve some interest of the person to whom the matter is published or of some third person; and (3) situations that involve a recognized interest of the public. Gist, 284 Ill. App. 3d at 372-73. A court should examine the occasion giving rise to the defamation action when determining as a matter of public policy whether the occasion created some recognized duty or interest that makes communication of the defamatory statement in that situation conditionally privileged as a matter of law. Gist, 284 Ill. App. 3d at 373.
If a defendant demonstrates the existence of a qualified privilege, the burden then shifts to the plaintiff to demonstrate an abuse of the privilege. The qualified privilege is abused if (1) the defendant acted with actual malice by making the statement with knowledge of its falsity or acting in reckless disregard as to the truth or falsity of the statement; or (2) the defendant committed “ ‘any reckless act which shows a disregard for the defamed party’s rights, including the failure to properly investigate the truth of the matter, limit the scope of the material, or send the material to only the proper parties.’ ” Gist, 284 Ill. App. 3d at 374, quoting Kuwik, 156 Ill. 2d at 30.
The plaintiff need prove the common-law elements of defamation only by a preponderance of the evidence, but when the defendant establishes the existence of a qualified privilege, the plaintiff must prove by clear and convincing evidence that the defendant acted with actual malice. Martin v. State Journal-Register, 244 Ill. App. 3d 955, 962 (1993). The trial court implements these standards when a party moves for summary judgment on a defamation claim. Martin, 244 Ill. App. 3d at 962, citing Anderson v. Liberty Lobby, Inc., 477 U.S. 242, 254, 91 L. Ed. 2d 202, 215, 106 S. Ct. 2505, 2513 (1986).
In Lovgren v. Citizens First National Bank of Princeton, 126 Ill. 2d 411 (1989), our supreme court set forth the three elements necessary to state a cause of action for false light invasion of privacy. First, the allegations in the complaint must show that the plaintiff was placed in a false light before the public as a result of the defendant’s actions. Second, the court must determine whether a trier of fact could decide that the false light in which the plaintiff was placed would be highly offensive to a reasonable person. Third, the plaintiff must allege and prove that the defendant acted with actual malice, that is, with knowledge that the statements were false or with reckless disregard for whether the statements were true or false. Lovgren, 126 Ill. 2d at 419-23.
In cases where both defamation and false light invasion of privacy claims might exist, the plaintiff may proceed under either theory, or both, but only one recovery for each instance of publicity is possible. Dubinsky, 303 Ill. App. 3d at 330. The claim of false light invasion of privacy protects one’s interest in being let alone from false publicity. Our supreme court has adopted section 652E of the Restatement (Second) of Torts, stating, “ ‘[o]ur study of the Restatement approach and Prosser’s commentary on false-light privacy reveals that the heart of this tort lies in the publicity, rather than in the invasion into the plaintiffs physical solitude or affairs upon which the tort of invasion into seclusion is based.’ ” Dubinsky, 303 Ill. App. 3d at 331, quoting Lovgren, 126 Ill. 2d at 418-19. In false light cases, a court need not distinguish between private and public figures, and a plaintiffs involvement in public matters does not automatically give the defendant the right to make or publish statements depicting the plaintiff in a false light. Dubinsky, 303 Ill. App. 3d at 331.
a. Statements regarding plaintiff’s performance
Plaintiff disputes the trial court’s conclusion that he is a public figure for purposes of this litigation. However, the court’s ruling on the issue is relevant only for determining whether defendant’s allegedly defamatory statements are privileged. The existence of a privilege would require plaintiff to prove by clear and convincing evidence that defendant acted with “actual malice.” In his reply brief, plaintiff makes the following concessions: “Plaintiff agrees that he must show actual malice on the defamation claim (Count I) to defeat any qualified privilege as to [defendant’s] letters to the [school] officials. Plaintiff also agrees that he must show actual malice as an element of his false light claim (Count II).”
Furthermore, plaintiff acknowledged during a deposition that he thought defendant sincerely believed each of the allegedly defamatory statements. A judicial admission is a party’s deliberate, clear, unequivocal statement about a concrete fact within the party’s peculiar knowledge. It is well settled that the party making the admission is bound by that admission and cannot contradict it. Eidson v. Audrey’s CTL, Inc., 251 Ill. App. 3d 193, 195-96 (1993). Although plaintiffs own pleadings and testimony tend to undermine his argument that defendant knew that the derogatory statements were false or made in reckless disregard as to their truth or falsity (see Gist, 284 Ill. App. 3d at 374), we conclude that plaintiff has not conceded that he cannot prove the malice element of defamation and false light invasion of privacy.
Plaintiff agrees that he must prove that defendant acted with actual malice in making the statements to the school officials. Therefore, his argument that he is not a public figure is rendered moot for the purposes of his defamation claim regarding those statements. In his reply brief, plaintiff alleges that defendant also communicated defamatory statements to the press, and that he need not prove that defendant acted with actual malice in making those statements because plaintiff is not a public figure. Plaintiff cites no authority for the proposition that the requirement of proof of actual malice depends on the recipient of the allegedly defamatory communication. Plaintiff does not explain why he need not prove actual malice regarding some of the allegedly defamatory statements and not others. See 210 Ill. 2d R. 341(e)(7) (“Points not argued are waived and shall not be raised in the reply brief, in oral argument, or on petition for rehearing”). Furthermore, we are aware of no authority that permits two different standards of proof to apply to a single count. See 735 ILCS 5/2 — 613(a) (West 2002) (“each [cause of action] shall be separately designated and numbered”). In light of the concessions in plaintiffs reply brief, we conclude that the single defamation count, as alleged, requires plaintiff to prove that defendant acted with actual malice when he made the statements to both the school officials and the press. Our disposition does not preclude plaintiff from seeking leave to amend his complaint to divide his defamation allegations into two counts. 735 ILCS 5/2 — 616 (West 2002). If plaintiff chooses to amend his complaint, the trial court may consider whether defendant’s communications to the press were privileged and whether he abused that privilege.
Plaintiff also alleges for the first time on appeal that defendant defamed plaintiff to the football parents. We conclude that plaintiffs new claim that defendant communicated defamatory statements to the parents is waived because the claim is not included in the complaint. See Haudrich v. Howmedica, Inc., 169 Ill. 2d 525, 536 (1996) (issues not raised in the trial court are waived and may not be raised for the first time on appeal). If plaintiff is to prevail on the defamation and false light counts as currently alleged, he must prove by clear and convincing evidence that defendant acted with actual malice. See Martin, 244 Ill. App. 3d at 962 (defamation); see also Douglass v. Hustler Magazine, Inc., 769 F.2d 1128, 1140 (7th Cir. 1985) (false light invasion of privacy).
The record contains evidence that defendant praised plaintiffs character and coaching ability at least twice from the fall of 1997 to the spring of 1998. A short time after his son began competing with plaintiffs son for the team’s quarterback position, defendant submitted the letters to Lamberson and Bruder harshly criticizing plaintiffs performance and referring to him as a “joke” and “buffoon.” The curious timing of defendant’s conduct suggests that a question of fact exists as to whether defendant acted knowingly or recklessly when he lobbied the two administrators to discharge plaintiff as coach.
Defendant next contends that summary judgment was nevertheless appropriate because his communications to Lamberson and Bruder qualify as a petition to a governmental body and, therefore, his statements are immunized under the Noerr-Pennington doctrine. See Eastern R.R. Presidents Conference v. Noerr Motor Freight, Inc., 365 U.S. 127, 5 L. Ed. 2d 464, 81 S. Ct. 523 (1961); United Mine Workers of America v. Pennington, 381 U.S. 657, 14 L. Ed. 2d 626, 85 S. Ct. 1585 (1965). Plaintiff responds that defendant’s novel argument is a “classic red herring.”
The Noerr-Pennington doctrine stems from a Supreme Court opinion holding that parties who petition the government for governmental action favorable to themselves cannot be sued under the Sherman Anti-Trust Act, even though their actions are motivated by anticompetitive intent. United Mine Workers of America v. Pennington, 381 U.S. 657, 670, 14 L. Ed. 2d 626, 636, 85 S. Ct. 1585, 1593 (1965). There is a notable amount of case law addressing the question whether the Noerr-Pennington doctrine brings first amendment principles to bear on state-law tort claims. See, e.g., South Dakota v. Kansas City Southern Industries, Inc., 880 F.2d 40, 50-51 (8th Cir. 1989) (applying first amendment analysis to a state claim for tortious interference with contractual relations), cert. denied, 493 U.S. 1023, 107 L. Ed. 2d 745, 110 S. Ct. 726 (1990); Brownsville Golden Age Nursing Home, Inc. v. Wells, 839 F.2d 155, 159-60 (3d Cir. 1988) (applying defamation and Noerr-Pennington analyses to tort claim based on the defendants’ actions in alerting authorities to plaintiffs violations of law); Havoco of America, Ltd. v. Hollobow, 702 F.2d 643, 649 (7th Cir. 1983) (applying Noerr-Pennington and its “sham litigation” exception “to protect the First Amendment right to petition against claims of tortious interference with business relationships”); Sierra Club v. Butz, 349 F. Supp. 934, 938-39 (N.D. Cal. 1972) (applying first amendment analyses of Noerr-Pennington and defamation cases to state counterclaim for interference with advantageous relationship); Florida Fern Growers Ass’n v. Concerned Citizens, 616 So. 2d 562, 569 (Fla. App. 1993) (declining to follow Sierra Club v. Butz). However, we are unaware of any Illinois case that has analyzed the NoerrPennington doctrine in the context of claims for defamation and false light invasion of privacy under state law.
In Westfield Partners, Ltd. v. Hogan, 740 F. Supp. 523 (N.D. Ill. 1990) , a land developer filed a suit for a deprivation of civil rights (42 U.S.C. § 1983 (1994)) against homeowners who had petitioned to prevent the development of a proposed roadway to acreage that the developer wanted to turn into “Tall Oaks Estates.” The court held that the defendants’ petitioning was absolutely privileged under the first amendment and based this privilege on the Noerr-Pennington doctrine. Westfield Partners, 740 F. Supp. at 525. The court noted that the defendants were sued for nothing more than exercising their right to petition their government.
This case is distinguishable. Counts I and II of the amended complaint are not directed toward defendant’s attempt to influence governmental decision making. Instead, plaintiff takes issue with alleged defamation and false light invasion of privacy that occurred during that petitioning. We conclude that the rule announced in McDonald v. Smith, 472 U.S. 479, 86 L. Ed. 2d 384, 105 S. Ct. 2787 (1985), is more instructive than the Noerr-Pennington doctrine. The defendant in McDonald sent defamatory letters to various governmental officials, including President Reagan and Representatives Jack Kemp and Barry Goldwater, Jr., concerning the plaintiffs ethical qualifications to serve as United States Attorney, a position for which he sought appointment. The plaintiff sued for common-law defamation in state court, and the case was removed to federal court based on diversity of citizenship. The defendant moved for judgment on the pleadings, arguing that the petition clause of the first amendment, which guarantees “the right of the people *** to petition the Government for a redress of grievances” (U.S. Const., amend. I), provided him with absolute immunity to make the defamatory statements. The Supreme Court disagreed, noting that “[u]nder state common law, damages may be recovered only if [the defendant] is shown to have acted with malice.” McDonald, 472 U.S. at 485, 86 L. Ed. 2d at 390, 105 S. Ct. at 2791. The Court held that “the Petition Clause does not require the State to expand [the first amendment] privilege into an absolute one. The right to petition is guaranteed; the right to commit libel with impunity is not.” McDonald, 472 U.S. at 485, 86 L. Ed. 2d at 390, 105 S. Ct. at 2791. The Court declined to “elevate the Petition Clause to special First Amendment status.” McDonald, 472 U.S. at 485, 86 L. Ed. 2d at 390, 105 S. Ct. at 2791.
The Court has elsewhere suggested that the Noerr-Pennington doctrine stems from the petition clause of the first amendment. See City of Columbia v. Omni Outdoor Advertising, Inc., 499 U.S. 365, 378, 113 L. Ed. 2d 382, 396-97, 111 S. Ct. 1344, 1353 (1991); see also LoBiondo v. Schwartz, 323 N.J. Super. 391, 414, 733 A.2d 516, 529 (1999) (“the right to petition government for redress of grievances exists entirely independently of Noerr-Pennington, and indeed, the NoerrPennington doctrine itself seems to derive from that fundamental right”). Therefore, we conclude that the Noerr-Pennington doctrine does not provide defendant with protection that would supplement a privilege that is not already conferred by the petition clause.
Defendant argues that he is entitled to absolute immunity under the Noerr-Pennington doctrine, which itself rests on the petition clause. We reject defendant’s argument because the Supreme Court clearly stated in McDonald that the petition clause does not bar a defamation claim as long as the plaintiff proves that the defendant acted with actual malice. Because counts I and II are related in that each requires a showing of actual malice, we similarly rely upon McDonald in rejecting defendant’s Noerr-Pennington defense to the false light invasion of privacy claim.
We conclude that, because a question of fact exists as to whether defendant acted with actual malice or a reckless disregard of plaintiffs rights, the trial court incorrectly granted defendant summary judgment on plaintiffs claims for defamation (see Gist, 284 Ill. App. 3d at 374) and false light invasion of privacy (see Lovgren, 126 Ill. 2d at 419-23) based on the statements to Lamberson, Bruder, and the press regarding plaintiffs performance in the role of football coach. On remand, the trial court should apply the clear-and-convincing-evidence standard to this factual question, unless plaintiff chooses to amend the complaint to allege a separate count of defamation for each statement recipient, in which case the result could be different.
b. Statements regarding plaintiff’s reputation among the football parents
Plaintiff alternatively claims defamation based on defendant’s statements to Lamberson and Bruder that many parents supported his campaign to remove plaintiff as football coach. The statements are defamatory per se because they tend to harm plaintiffs reputation by imputing widespread disapproval among the parents of the children he coached. In Illinois, an allegedly defamatory statement is not actionable if it is substantially true, even though it is not technically accurate in every detail. Gist, 284 Ill. App. 3d at 371. While this rule is rooted in the United States Constitution, it is also logically driven, as “ ‘falsehoods which do no incremental damage to the plaintiffs reputation do not injure the only interest that the law of defamation protects.’ ” (Emphasis in original.) Gist, 284 Ill. App. 3d at 371, quoting Haynes v. Alfred A. Knopf, Inc., 8 F.3d 1222, 1228 (7th Cir. 1993).
A defendant bears the burden of establishing the “substantial truth” of his assertions, which he can demonstrate by showing that the “gist” or “sting” of the defamatory material is true. Gist, 284 Ill. App. 3d at 371. When determining the “gist” or “sting” of allegedly defamatory material, a trial court must “ ‘look at the highlight of the article, the pertinent angle of it, and not to items of secondary importance which are inoffensive details, immaterial to the truth of the defamatory statement.’ ” Gist, 284 Ill. App. 3d at 371, quoting Vachet v. Central Newspapers, Inc., 816 F.2d 313, 316 (7th Cir. 1987). While substantial truth is normally a question for the jury, where no reasonable jury could find that substantial truth had not been established, the question is properly one of law, which this court may review de novo. Gist, 284 Ill. App. 3d at 371.
Defendant’s November 8, 2000, letter to Lamberson listed the names of 105 football parents and 36 players who purportedly signed the petition. Apparently in the interest of candor, defendant also included the names of several other football parents who declined to sign the petition. During discovery, defendant produced the signatures of only 29 parents and 23 players who actually supported the petition, but defendant’s motion for summary judgment included supporting statements from 42 parents. Attached to plaintiffs amended complaint were affidavits in which six parents testified that defendant falsely reported to Lamberson that they had signed. Although we do not condone defendant’s misrepresentation, we conclude that he established the gist of his assertion that many parents did not approve of plaintiffs performance as coach. Because no reasonable jury could find by clear and convincing evidence that defendant had not established the substantial truth of that particular statement, we conclude that the trial court properly resolved the question on defendant’s motion for summary judgment. See Gist, 284 Ill. App. 3d at 371; see also Martin, 244 Ill. App. 3d at 962.
The dissent contends that the positive denials of a few parents support plaintiffs claims of defamation and false light invasion of privacy. We respectfully disagree. Although the six parents’ affidavits verify plaintiffs assertion that defendant exaggerated the level of discontent among all of the parents, they do not establish “ ‘incremental damage to the plaintiffs reputation.’ ” (Emphasis in original.) Gist, 284 Ill. App. 3d at 371, quoting Haynes, 8 E3d at 1228. If we were to adopt the dissent’s view, we would effectively eliminate the defense of substantial truth in defamation and false light cases; only absolute truth would bar such claims. See Gist, 284 Ill. App. 3d at 371.
2. Interference with Prospective Economic Advantage
Finally, we consider plaintiffs argument that he is entitled to a trial to determine whether defendant improperly interfered with plaintiffs employment as football coach. “ ‘To state a cause of action for intentional interference with prospective economic advantage, a plaintiff must allege (1) a reasonable expectancy of entering into a valid business relationship, (2) the defendant’s knowledge of the expectancy, (3) an intentional and unjustified interference by the defendant that induced or caused a breach or termination of the expectancy, and (4) damage to the plaintiff resulting from the defendant’s interference.’ ” (Emphasis added.) Voyles v. Sandia Mortgage Corp., 196 Ill. 2d 288, 300-01 (2001), quoting Anderson v. Vanden Dorpel, 172 Ill. 2d 399, 406-07 (1996).
Plaintiff argues that the causation element is an unresolved question of fact precluding the entry of summary judgment. Plaintiff cites Bruder’s testimony that defendant told her that he would work toward her removal as the athletic director if she did not terminate plaintiffs employment as the football coach. However, both Bruder and Lamberson testified that defendant’s conduct did not affect the decision to remove plaintiff as the coach. Plaintiffs assertion as to the importance of defendant’s threat to Bruder is speculative and contrary to the unequivocal and uncontroverted testimony of Bruder and Lamberson.
The dissent asserts that “it is error for the majority to presuppose that even uncontroverted testimony from Bruder and Lamberson would not raise a material question of fact, because it is the fact finder’s province to assess the credibility of Bruder and Lamberson.” 348 Ill. App. 3d at 924 n.1. This statement runs contrary to the well-settled rule that a party opposing a motion for summary judgment may not rely upon his pleadings alone to raise an issue of material fact to rebut uncontradicted facts introduced by the moving party. Hermes, 226 Ill. App. 3d at 824. Plaintiff has offered no evidence to impeach Bruder and Lamberson, and we decline to speculate, as the dissent does, that the timing of their decision and their awareness of defendant’s efforts render their unequivocal testimony incredible. Plaintiffs claim fails because he offers no evidence to establish that defendant’s conduct induced or caused a breach or termination of plaintiffs employment as the school’s head football coach. Therefore, the trial court correctly granted defendant summary judgment on the claim of interference with prospective economic advantage.
We reverse the entry of summary judgment on the defamation and false light invasion of privacy claims, affirm the entry of summary judgment on the claim of interference with prospective economic advantage, and remand the cause for proceedings that are consistent with this opinion.
Affirmed in part and reversed in part; cause remanded.
McLAREN, J., concurs.