He might mean "injurious falsehood"
"One such tort is called by various names such as 'disparagement of property,' 'slander of goods,' 'commercial disparagement,' and 'trade libel.' The tort is 'now generally referred to as `injurious falsehood.' " Bankwest v. Fidelity Deposit Co., Maryland, 63 F.3d 974 (10th Cir. 1995) "Under Utah law, injurious falsehood combines the two related torts of slander of title and trade libel. To establish a claim for injurious falsehood, plaintiff 'must prove falsity of the statements made, malice, and special damages.' [...] As to the first element of an injurious falsehood claim, although some courts have interpreted the tort more broadly, to be actionable under Utah law, the false statements must either disparage plaintiff's title or the quality of plaintiff's product." IHC Health Servs. Inc. v. ELAP Servs., LLC, Case No. 2:17-cv-01245-JNP-EJF (D. Utah Sep. 28, 2018)