What differs in a defamation suit when the plaintiff is a public figure, as opposed to when the plaintiff is not a public figure?

a) Punitive damages are available.

b) The plaintiff need not prove actual injury to the reputation.

c) The plaintiff can recover even when the statement is a mere opinion.

d) The plaintiff must prove that the statement was made with malice.

e) The plaintiff must prove that the statement was made in writing.