It is not necessary that the publication impute a crime, for the offense may be committed by imputing to another the doing of many acts which are not criminal. Thus to publish of another that he is a scoundrel is libel.143

So a collection agency in attempting to collect claims by addressing a debtor through the mail using envelopes with the words, "Bad debt collecting agency," printed on them commits libel, such words tending and being intended to expose the persons to whom sent to contempt and bring them into disrepute with their employers and the public.144

So also a publication charging that a person had become insane in the persecution of his political opponent, and that his insane prejudice and hatred would become contagious and result in murder is criminal libel.145