An examination of recent cases involving press releases and public relations writers indicates that courts have devised several ways, including the use of guidelines set out by the Ollman (from "Ollman v. Evans") four-factor test, to make the distinction between fact and opinion. The four-factor test helps courts to assess (1) whether the statement in question has a precise core of meaning for which a consensus exists, or whether it is ambiguous; (2) the degree to which the statement is verifiable; (3) the context in which the statement is made including the use of cautionary language and the tone of the whole; and (4) the broader context in which the statement appears. Because press releases have still been subject to libel suits, such as in "Parks v. Steinbrenner," where the court ruled that the press release did not set forth adequate statement of facts to support the opinions within the release, authors of releases are advised to try to avoid libel suits by disclosing the facts on which the opinions are based. Additionally, writers can choose words with ambiguous meanings, use rhetorical hyperbole, and make tongue-in-cheek statements. They can also preface statements with "I think," and similar phrases, and surround questionable words with quotation marks: "rapist,""lied." Despite criticism of the Ollman four-factor test, writers are advised to apply the test to their own writing to determine whether fact is discernable from opinion. (JC)