How can a person be defamed without being named directly in a publication?

In the context of defamation law, a person does not need to be explicitly named to be defamed, provided they are "ascertainable" to those who read or hear the publication.1

For a claim to be successful when a person is not directly named, the statements must be interpreted according to common usage and the context of the publication. In the landmark case New York Times Co. v. Sullivan, L.B. Sullivan, a police commissioner, successfully argued in state court that he was defamed by an advertisement that did not name him but cast aspersions on the police force he led.12

Regarding groups or classes of people, defamation is generally only actionable if the statements refer to all members of that class—particularly if the group is small—or if specific members are specially imputed. Ultimately, the law requires that the individual be identifiable as the target of the false, reputation-damaging communication.1