Because a reasonable factfinder could not conclude that "Butt-Head Astronomer" implied that Plaintiff was a less than able astronomer or that Plaintiff was legally wrong in asking Defendant to cease using Plaintiff's name, the only remaining assertion is the bare statement that Plaintiff is a "Butt-Head Astronomer." Clearly this phrase cannot rest on a core of objective evidence. Plaintiff does not suggest any other assertions of objective fact that could be reasonably implied from the phrase.
Based on an analysis of the factors identified in Unelko, the Court has no reason to conclude that the statement made by Defendant implies an assertion of objective fact. Milkovich, 497 U.S. at 21, 110 S. Ct. at 2707 . Therefore, the statement is protected under the First Amendment and cannot form the basis of a claim for libel.