Parsi v. Daioleslam, 852 F. Supp. 2d 82

Plaintiffs Trita Parsi and the National Iranian American Council sue Seid Hassan Daioleslam for defamation and false light.
Defendant published numerous English-language articles about NIAC and Parsi on websites such as iranianlobby.com.
Plaintiffs proffer two experts, Debashis Aikat and Joel Morse, to support their claims.
Defendant moves to exclude both experts under Federal Rule of Evidence 702.
The Court applies Daubert/Kumho Gates and weighs reliability and helpfulness under Rule 702 and 403.
The Court excludes both Aikat and Morse as unreliable and/or unhelpful, granting the motions in limine.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Aikat's testimony is admissible under Rule 702.	Aikat should be allowed; standard of care is professional journalism guidelines.	Aikat's methodology and sources are too vague and biased.	Excluded; not reliable under FRE 702.
Whether Morse's testimony is admissible under Rule 702.	Morse's damages analysis is admissible to prove lost revenue.	Morse's methodology contains multiple errors/arbitrary assumptions.	Excluded; not reliable under FRE 702 and 403.

Daubert v. Merrell Dow Pharm., Inc., 509 U.S. 579 (Supreme Court (1993)) (gatekeeping standard for expert reliability)
Kumho Tire Co., Ltd. v. Carmichael, 526 U.S. 137 (Supreme Court (1999)) (flexible inquiry for specialized knowledge)
General Electric Co. v. Joiner, 522 U.S. 136 (Supreme Court (1997)) (conclusions as to reliability linked to data/methodology)
United States v. Gatling, 96 F.3d 1511 (D.C. Cir. 1996) (Rule 403/702 balance in admitting expert testimony)
In re Air Crash Disaster at New Orleans, La., 795 F.2d 1230 (5th Cir. 1986) (expert testimony must have factual basis and methodological rigor)
Joy v. Bell Helicopter Textron, Inc., 999 F.2d 549 (D.C. Cir. 1993) (scenarios must have factual basis; speculative models risky)
Morse v. (illustrative parallel), - (-) ((referenced for methodological critique))