Malia Zimmerman | Media Matters for America

Malia Zimmerman

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  • Fox’s Seth Rich conspiracy theorists: Where are they now?

    Blog ››› ››› MATT GERTZ

    Melissa Joskow / Media Matters

    Fox News didn't deliver on its promised Seth Rich coverage investigation, so Media Matters is doing it instead. This is the fourth in a series marking the two-year anniversary of Fox’s publication of a story -- retracted seven days later -- that promoted the conspiracy theory that the murdered Democratic National Committee staffer, and not the Russians, had provided the DNC emails to WikiLeaks. Read part one, part two, part three, part four, and our timeline of events.

    No one has been held accountable for Fox News’ promotion of conspiracy theories about murdered Democratic National Committee staffer Seth Rich.

    Thursday marked the two-year anniversary of Fox News’ publication of a dubiously thin, hastily edited article pushing the debunked claim that Rich had provided DNC emails to WikiLeaks. After the story crashed and burned, Fox retracted it and promised to investigate what happened.

    With no explanation forthcoming and no punishments announced two months after the story’s retraction, some Fox staffers voiced their displeasure to CNN’s Oliver Darcy. One Fox staffer told CNN that “people need to start getting canned” over the story.

    But another senior Fox News employee quoted in the story was more resigned about the situation, arguing that the lack of transparency and accountability was unsurprising for the network: “No one ever gets fired from Fox for publishing a story that isn't true.”

    The more cynical Fox staffer was correct.

    Two years later, no one involved in producing or pushing the retracted Rich story has been publicly disciplined, and several have actually been promoted.

    It’s clear, as the anonymous senior Fox employee indicated, that the network has no interest in journalistic integrity or employee accountability. The purported “investigation” was a scam intended to make it look like Fox was taking its responsibilities seriously until the anger over its actions dissipated.

    Here is what has become of the network’s conspiracy theorists:

    Malia Zimmerman is the investigative reporter who wrote the original story that the network later retracted. She still apparently works at the network but has not published a new story since August 2017, soon after she and the network were sued over the story.

    Greg Wilson, then deputy managing editor of, reportedly edited Zimmerman’s story, rushing to publish it in spite of its flaws because a rival story on the subject was going viral. One month after the story’s publication, Fox promoted him to managing editor of

    Sean Hannity, one of the network’s star prime-time hosts, championed the Rich conspiracy theory on Fox long after the story had collapsed. Some Fox employees told The Daily Beast they were embarrassed by his antics and network executives reportedly directed him to stop talking about Seth Rich after he lost advertisers and jeopardized a major acquisition deal in the U.K. But he has retained his show, which moved to the more coveted 9 p.m. timeslot later that year, continued to show disregard for anything resembling journalistic ethics and pushed conspiracy theories about how WikiLeaks obtained the DNC emails as recently as this April.

    Porter Berry, the executive producer of Hannity’s Fox show at the time, was the recipient of a letter from Rich’s brother Aaron who urged him to find “decency and kindness” and stop promoting the conspiracy theories. In August 2018, Fox promoted him to vice president and editor-in-chief of Fox News Digital, a role in which he oversees all of the network’s digital content, including,, and the Fox News apps.

    Laura Ingraham, then a Fox contributor, suggested on-air that the Rich family was covering up his death for partisan gain. In September 2017, Fox announced that she would host her own prime-time show for the network.

    Newt Gingrich, a Fox contributor, claimed on-air that Rich had been “assassinated” for giving WikiLeaks DNC emails. He has repeatedly refused to retract his despicable comments. He still has his Fox platform.

    Fox correspondent Griff Jenkins, the hosts of Fox & Friends and Fox & Friends First, Fox Business host Lou Dobbs, senior judicial analyst Andrew Napolitano were among the on-air network personalities who pushed the conspiracy theories. None appear to have been disciplined in any way.

  • Fox News' retracted reporting on Seth Rich is even worse than you remember

    The article was based almost entirely on two sources: one anonymous, one discredited

    Blog ››› ››› MATT GERTZ

    Melissa Joskow / Media Matters

    Fox News didn't deliver on its promised Seth Rich coverage investigation, so Media Matters is doing it instead. This is the first in a series marking the two-year anniversary of Fox’s publication of a story -- retracted seven days later -- that promoted the conspiracy theory that the murdered Democratic National Committee staffer, and not the Russians, had provided DNC emails to WikiLeaks. Read part two, part three, part four, part five, and our timeline of events

    When Fox News’ stable of unhinged propagandists draw public criticism, its executives tell observers to focus on the network's “news” side, which supposedly provides credible reporting and follows the industry’s standards. But it was the “news” side that was responsible for Fox’s most calamitous failure in recent memory, in which the network repeatedly promoted conspiracy theories about murdered former Democratic National Committee staffer Seth Rich. And two years later, despite a purported internal investigation into what went wrong with the network’s coverage, no one at Fox has been held accountable.

    In July 2016, the online fever swamp linked together two unrelated events: Rich’s tragic murder on July 10 in what police determined was an unsolved botched robbery and WikiLeaks’ July 22 release of thousands of internal DNC emails whose contents damaged Democratic nominee Hillary Clinton’s presidential campaign. Conspiracy theorists speculated -- based almost entirely on the facts that Rich had worked at the DNC and that his murder had been unsolved -- that Rich been killed in retaliation for giving the emails to WikiLeaks.

    In reality -- as the U.S. intelligence community concluded in January 2017, as did special counsel Robert Mueller in 2019 -- Russian hackers had given the emails to WikiLeaks as part of a successful effort approved at the highest levels of the Kremlin to support Donald Trump’s presidential run. But in order to raise doubts about that conclusion, prominent U.S. conservatives and WikiLeaks founder Julian Assange would repeatedly suggest that Rich had been the real source of the emails.

    On May 16, 2017, 10 months after Rich’s death, Fox News put itself firmly behind that conspiracy theory with a despicable and eventually retracted online article and a series of on-air segments.

    Rereading the original story, it’s still disturbing that something so poorly conceived and thinly-sourced could have made it to Fox’s website in the first place.

    Fox’s story was the result of a collaboration between an unlikely trio: Fox News investigative reporter Malia Zimmerman, who “has a history of publishing questionable stories” based on anonymous sources and claimed to have been working on the story for 10 months; Fox contributor Rod Wheeler, a private investigator who had been hired by the Rich family to review the case; and Ed Butowsky, a businessman and “reliable Republican surrogate” who Wheeler says had connected him to the Riches, paid for his work, and brought him to Zimmerman’s attention.

    The result was what Fox termed a “bombshell” story that included three extraordinary claims. Zimmerman’s report suggested that Rich had been in contact with a WikiLeaks representative before he died, that he had provided that contact with tens of thousands of DNC emails, and that a vast conspiracy theory helmed by the DNC and Clinton had covered up the truth.

    By the time Fox ran Zimmerman’s story, the notion that Rich had given the DNC emails to WikiLeaks was widely recognized as a conspiracy theory, one contradicted by the U.S. intelligence community’s findings in its January 2017 report that Russian intelligence agents had hacked the DNC and given the emails to WikiLeaks.

    One would expect a story purporting to dispute the conclusions of the U.S. intelligence community to provide substantial and serious evidence. Instead, Zimmerman’s report for Fox was based almost entirely on two sources -- one anonymous and one discredited.

    Fox prints a claim from a single anonymous source that Rich gave WikiLeaks the DNC emails

    Zimmerman’s anonymous source -- a “federal investigator” from an unnamed agency -- purportedly told her that he had read an FBI report that detailed the contents of Rich’s computer, had “seen and read the emails” between him and WikiLeaks Director Gavin MacFadyen, and that Rich had sent thousands of DNC emails exchanged between January 2015 and late May 2016 to MacFadyen before May 21, 2016.

    Zimmerman claimed to have spent 10 months investigating Rich’s death, but she provided no other information corroborating the source’s statement. MacFayden had died of lung cancer in October 2016, so he couldn’t be reached to corroborate the story. But Zimmerman had no comments from any of his associates verifying that he received documents from Rich either.

    The U.S. intelligence community is not infallible, but it beggars belief that a news outlet would publish a purported debunking of its claims based on such scanty evidence.

    Fox prints its contributor’s unsupported claim of a Rich cover-up

    Later in the article, Zimmerman included this extraordinary claim:

    Wheeler believes powerful forces are preventing the case from a thorough investigation.

    “My investigation shows someone within the D.C. government, Democratic National Committee or Clinton team is blocking the murder investigation from going forward,” Wheeler told Fox News. “That is unfortunate. Seth Rich’s murder is unsolved as a result of that.”

    There are several major problems with this claim. First, Zimmerman provided no additional sources in the police department or elsewhere signing on to this theory -- it relied entirely on Wheeler’s say-so.

    Second, Zimmerman published this claim without including any information about why Wheeler believed this to be the case. He questioned why the police hadn’t been forthcoming about releasing video of Rich's murder Zimmerman's sources say exists and speculated that Rich may have given police information about his murderer before he died. But Zimmerman gave no explanation about why this led Wheeler to conclude that “powerful forces” were behind the events, much less why he named the DNC or Clinton specifically.

    Third, Wheeler is not a credible source for information -- as BuzzFeed reported, before his involvement in the Rich case, he was “mostly known for saying outrageous things on air” as a Fox contributor.

    And fourth, Wheeler subsequently alleged in a lawsuit that Zimmerman fabricated that quote, which either shows massive malfeasance on her part or provides more evidence that he is not a reliable narrator whose claims should be taken seriously. (In dismissing the suit, a federal judge concluded that Wheeler had not proved he was misquoted and that having “embarked on a collective effort to support a sensational claim regarding Seth Rich’s murder” he “cannot now seek to avoid the consequences of his own complicity and coordinated assistance in perpetuating a politically motivated story not having any basis in fact.”)

    Fox relies on the same two sources to “corroborate” report that Rich was WikiLeaks' source for the DNC emails

    Zimmerman’s only “corroboration” of her anonymous source’s claim that he read the FBI report that showed Rich and WikiLeaks’ MacFayden were in contact was that the claim “is consistent” with Wheeler’s probe. She reported that Wheeler told her: “My investigation up to this point shows there was some degree of email exchange between Seth Rich and WikiLeaks. … I do believe that the answers to who murdered Seth Rich sits on his computer on a shelf at the DC police or FBI headquarters.” But again, Zimmerman presented this assertion without producing any evidence to back it up, and Wheeler later claimed that that quote had also been fabricated.

    This was all the evidence Fox apparently required to publish a story promoting the conspiracy theory. And the network’s on-air talent picked it up from there, with Zimmerman’s report trumpeted to audiences of millions on shows like Fox & Friends, Lou Dobbs Tonight, and Hannity.

    Fox reportedly published the story because it had been scooped

    How could did this happen? CNN’s Oliver Darcy provided an explanation in an August 2017 report. In this telling, the “frenzied saga” that led to the story’s publication “took place over a period of less than 24 hours”: Zimmerman had filed a draft of her story, but it had “no concrete publish date.” But Wheeler set the wheels in motion by telling a reporter for local Fox affiliate WTTG all about the story that he said Fox News was preparing to publish. Within hours on May 15, WTTG ran a segment pushing the Rich conspiracy theory based on the reporter’s interview with Wheeler.

    CNN reported that when that story went viral on conservative media outlets, a top Fox News digital editor responded by publishing Zimmerman’s story without subjecting it to the usual editorial process:

    By the time Greg Wilson, who was at the time deputy managing editor of, entered the office on the morning of May 16, the story was everywhere. Even "Fox & Friends," the network's morning show, did two segments on the case based largely on WTTG's report. Wilson rushed to prepare Fox News' own article -- which included quotes attributed to Wheeler -- for publication and set it live on the website. Zimmerman's story soon replaced the previous text on the Fox News website and was featured on the homepage as the top story.

    It's not clear exactly what kind of vetting, if any, the article went through during the rush to publish it and stake Fox News' claim to the story. A person familiar with the situation told CNN that at least two steps in the usual vetting for an article like this -- review by Refet Kaplan, managing director of, and by the network's legal team -- did not happen.

    Zimmerman’s story began collapsing almost immediately under scrutiny from more credible news outlets, which reported that the FBI was “not involved in the case” and that Rich’s computer email activity did not indicate he had even been in contact with WikiLeaks. The other reporting also included denials from the Rich family and the Washington, D.C., police and looked into both Wheeler and Butowsky. Meanwhile, Wheeler began walking back the article’s claims.

    Fox promised an investigation into the story, then went quiet

    Following a week of brutal coverage, Fox finally retracted Zimmerman’s article. The piece was replaced with an editor’s note which claimed that the article “was not initially subjected to the high degree of editorial scrutiny we require for all our reporting” and that upon further review, it was “found not to meet those standards.”

    The note further promised to investigate how the story had been published and release that information publicly. But two years later, no such updates have been provided. Does Fox believe that Zimmerman’s anonymous source wasn’t credible? Does the network feel that its own contributor’s investigation was not sufficient to report on? We still don’t know.

    Fox has not held any of the people involved in the story’s publication accountable either. Zimmerman is apparently still a Fox reporter; Greg Wilson, the story’s editor, was subsequently promoted; and none of the on-air talent that promoted the conspiracy theory even apologized.

    And with no accountability for such a monstrous failure from the network’s “news” side, there’s every reason to suspect that something like this will happen again.

  • Fox’s “investigation” of its Seth Rich reporting is an obvious, predictable sham

    Blog ››› ››› MATT GERTZ

    Sarah Wasko / Media Matters

    Fox News’ employees, reports CNN’s Oliver Darcy, are “perplexed” with the state of an ongoing internal investigation into their network’s since-retracted May reporting on the murder of Democratic National Committee staffer Seth Rich. A lawsuit filed against the network by one of the report’s subjects thrust the story back into the news this week, and beset by a new wave of criticism, Fox’s journalists want their questions answered: Why Fox has not given a public accounting of why it published a report, based on shoddy evidence, indicating Rich was in contact with WikiLeaks shortly before he was killed? Why does Malia Zimmerman, the reporter who wrote the story, continue to publish pieces on Did a “top editor” review the story before its publication? And most of all, why has no one has been fired over the journalistic disaster nearly three months after it imploded?

    The answer to all these questions is the same: That’s the way Fox operates.

    Fox does not conduct internal investigations because the network’s executives want to get to the bottom of failures and hold people accountable. Fox conducts investigations when the heat is on and executives need to make it look like they are doing something about it. Their reviews are a public relations exercise that give them time to assess whether the level of criticism demands action, not an effort to maintain high ethical standards.

    If Fox was actually serious about maintaining its journalistic integrity after descending into the sewer by promoting long-debunked Rich conspiracy theories, the network would have long since fired Zimmerman, the story’s editor, and Sean Hannity, the Fox host who kept promoting the story long after it fell apart.

    CNN had a story about Anthony Scaramucci fall apart in late June. The network’s response to the situation was very different from Fox’s interminable Rich review. CNN’s piece was published, investigated, and retracted over the course of a weekend. By that Monday, the story’s reporter, editor, and the head of the investigations division -- all highly credentialled veteran journalists -- had resigned. On Fox’s airwaves, this was seen as a sign of weakness, evidence of CNN’s “major credibility crisis,” as Hannity put it. But that’s what real news outlets do when they screw up -- figure out what went wrong as quickly and thoroughly as possible, and hold their journalists accountable.

    That’s not how things work at Fox. The network killed its internal investigation into sexual harassment after firing CEO Roger Ailes last year, choosing to, as Vanity Fair put it, get “the revenue machine back on track” once the media firestorm died down rather than expanding its assessment to examine Fox’s broader culture. A similar investigation into Bill O’Reilly bought the network time to assess the blowback the reports that he had sexually harassed colleagues had caused; once it became clear that ongoing advertiser boycotts threatened the bottom line, the longtime star host was shown the door. Faced with a decades-long culture problem the network did as little as possible to stop the immediate criticism, using these internal reviews as a tool to manage the blowback.

    The review Fox launched in the wake of its bogus Rich story focuses on the quality of the journalism the network produced, not the horrendous behavior of its employees. But the principle of the investigation remains the same: It was an effort to defuse widespread public criticism, not to get to the bottom of what happened and punish those responsible.

    As CNN’s Darcy explains, it should have been extremely easy for Fox to have done a quick, comprehensive investigation into its Rich reporting, if that was what executives wanted to do. The network employs all the key players involved in producing the story, and presumably it has access to Zimmerman’s notes and communications. The simplest explanation for why the review yielded no result is that it was a sham. Perhaps the network went through the motions, looked into the claims a bit, then sat on its findings; perhaps Fox announced an investigation and simply never followed through. Either way, the point was to stall, to act like it was doing something and wait for the rest of the press to move on. That worked, until the lawsuit put the network’s reporting back under the spotlight. Maybe now the heat has risen high enough that Fox will actually have to act, though it’s certainly possible those in charge are hoping attention will shift again and they can continue to make no response.

    It is extremely unusual for such a review to happen at Fox in the first place. When the network’s reporting is bogus and there is enough attention on the failure, Fox will usually issue an apology, as anchor Bret Baier did last year after his report that Hillary Clinton was on the verge of being indicted collapsed. In a more extreme case, as we saw with senior judicial analyst Andrew Napolitano’s nonsense claim that a British intelligence service had spied on Donald Trump on President Barack Obama’s behalf, the network might issue a brief suspension.

    But that’s as far as accountability tends to go at Fox -- as a senior network source explained to Darcy, “No one ever gets fired from Fox for publishing a story that isn't true.” And the higher up in the network’s pantheon you are, the less chance you will be held to account. It seems significant that while Fox’s staffers are whispering to Darcy about how shameful it is that Zimmerman remains on the payroll, no one even bothers to suggest that there should be repercussions for Hannity, who melted down over the story, continuing to trumpet it after key details were called into question, and never admitted fault or apologized. If this investigation is serious, it should end with his termination.

    "I think the lack of transparency is not that surprising," the senior Fox News employee told Darcy. "But it really forces the question, how much journalistic integrity does Fox News really have?” Not much, pal. Welcome to the party.

  • Roger Stone says he's in communication with the White House about the Seth Rich lawsuit

    Stone was one of the first to push conspiracy theories about Rich’s murder, and he has called on Rich’s parents to be “charged with obstruction” of the investigation into their son’s death

    Blog ››› ››› TIMOTHY JOHNSON

    Roger Stone is doing damage control following the filing of a lawsuit alleging a scheme by Fox News and Trump administration officials -- including possibly the president himself -- to use the murder of Democratic National Committee staffer Seth Rich to absolve the Trump campaign of accusations it coordinated with Russia.

    During an appearance on Alex Jones’ conspiracy theory program, Stone said that officials he has spoken to at the White House are calling the lawsuit “bogus” and that he thinks the lawsuit will be dismissed “summarily.”  

    NPR reported on August 1 on a defamation lawsuit filed by Fox News contributor Rod Wheeler against 21st Century Fox, Fox News, Fox News reporter Malia Zimmerman, and frequent Fox guest Ed Butowsky.

    Wheeler alleges that Zimmerman published fake quotations attributed to him in a since-retracted May 16 story about Rich, and that Trump administration officials, including the president himself, were involved in crafting the story. The retracted story suggested that Rich, rather than Russia, provided WikiLeaks with emails stolen from the Democratic National Committee.

    Former White House press secretary Sean Spicer acknowledged to NPR that he did meet with Butowsky and Wheeler prior to the story’s publication. The lawsuit also alleges that Trump himself reviewed the Zimmerman story before it ran.

    Rich was murdered in Washington, D.C., in July 2016 in what local police believe was a botched robbery attempt. Conspiracy theories began spreading within weeks of Rich’s death and percolated throughout fringe right-wing media for nearly a year before finally exploding into the national conversation thanks to Fox News host Sean Hannity, who continuously hyped Zimmerman’s May 16 report.

    During the August 1 broadcast of conspiracy theory program The Alex Jones Show, Stone, a longtime Trump adviser, said, “My sources at Fox and my sources in the White House tell me that the lawsuit filed by the black private investigator, former D.C. police officer, is completely and totally bogus.” Stone also added that he thinks the lawsuit will be quickly dismissed.

    Stone was one of the first prominent figures to promote conspiracy theories about Rich’s death.  

    On August 9, 2016, less than a month after Rich’s death, Stone included Rich in a group of four murdered people for whom he blamed the Clintons:

    In recent months, Stone has turned his sights on Rich’s parents, first calling their behavior regarding the investigation into their son’s death “suspicious,” and most recently saying that Rich’s “parents should be charged with obstruction" of the investigation.

  • Trump administration met with a GOP donor and a Fox contributor about a fake story meant to distract from Russia probe

    A new lawsuit alleges that Trump personally helped Fox create fake news regarding Seth Rich, and Sean Spicer admits that he took a meeting with two people involved in the story

    Blog ››› ››› ALEX KAPLAN

    Sarah Wasko / Media Matters

    A new NPR report confirms that the Trump administration met with a Republican donor and Fox News contributor Rod Wheeler about a now-debunked report that pushed false claims about Seth Rich, a deceased Democratic National Committee (DNC) staffer. As reported by NPR, according to a subsequent lawsuit filed by Wheeler, the donor gave talking points about the Rich conspiracy theory not only to Wheeler but also to other Fox News employees, messaging that was then parroted on Fox & Friends and Sean Hannity’s show.

    Wheeler's lawsuit also alleges that President Donald Trump helped with the article in order to distract from the ongoing controversy about Trump’s possible ties to Russia. Trump, people in Trump’s inner circle, and Fox News have all previously spread fake news and downplayed and delegitimized efforts to counter the spread of fake news.

    In May, a Fox affiliate in Washington, D.C., claimed that Wheeler, who is a private investigator, said police had told him that they were told to stand down regarding the death of Rich, a DNC staffer killed in what law enforcement has concluded was likely a botched robbery attempt. The affiliate also said that Wheeler said it was “confirmed” that Rich had spoken to WikiLeaks, which published thousands of leaked DNC emails during the 2016 presidential campaign. reporter Malia Zimmerman subsequently published an article on the site quoting Wheeler as saying, “My investigation up to this point shows there was some degree of email exchange between Seth Rich and WikiLeaks,” and, “My investigation shows someone within the D.C. government, Democratic National Committee or Clinton team is blocking the murder investigation from going forward.” According to the lawsuit, in conjunction with the story, the Republican donor who brought Wheeler and Zimmerman together also suggested talking points to "various Fox News producers" and Fox & Friends on-air personalities, as well as to Wheeler for use on Hannity’s program. Both Fox News shows parroted the suggested messaging within days.

    But the story was quickly debunked, with Wheeler admitting he had no evidence and D.C. police saying Wheeler’s supposed claim was false. Fox News was forced to later retract the story. Yet Hannity, who ran with the report, continued to push the conspiracy theory even after the retraction.

    Wheeler, in an August 1 lawsuit against 21st Century Fox, Fox News, Zimmerman, and the Republican donor, investor/Trump supporter Ed Butowsky, now claims that Zimmerman made up those quotes she attributed to him. Wheeler claims that Trump was given the article in advance to review and urged its publication, and that the supposedly fabricated quotes were published “because that is the way the President wanted the article.” Wheeler added that Zimmerman and Butowsky, who bankrolled Wheeler’s original investigation into Rich’s murder, “had created fake news to advance President Trump’s agenda.” Former White House press secretary Sean Spicer -- who had said in May that he knew nothing about the story -- has now confirmed to NPR that he met with Wheeler and Butowsky to discuss the article before it was published, adding that he did not know of any involvement by Trump.

    Here’s audio of Spicer denying knowledge of the Rich story in May:

    The allegations come after Trump and his inner circle have worked tirelessly to cloud the actual meaning of fake news while spreading fake news stories themselves. Trump and his aides, echoing right-wing media including Fox News, have repeatedly called legitimate news stories and outlets they do not like “fake news.” People close to Trump, including former national security adviser Michael Flynn, have pushed fake news -- as has Trump himself. Additionally, federal investigators are looking into whether Trump’s 2016 campaign digital operation, headed by Brad Parscale along with Cambridge Analytica, a data analytics firm hired by the campaign, colluded with Russia to target voters in specific states with fake news.

    And this would also not be the first time that Fox News has spread fake news. Last October, Fox hosts Howard Kurtz and Megyn Kelly both reported a fake news story that then-Democratic presidential nominee Hillary Clinton called supporters of her primary opponent Bernie Sanders a “bucket of losers.” Kelly subsequently apologized for reporting the fake quote. In April, published an article from the British tabloid The Sun that reported fake news originating from Russian state media; Fox later removed the article after The New York Times asked the outlet about it. Additionally, Fox News repeatedly tried to minimize and dismiss concerns about fake news after the 2016 election, calling them "nonsense” and “a fake story,” and claiming that fake news is actually just “in the eye of the beholder." And when Facebook considered (and later implemented) the idea of partnering with fact-checking organizations to fact-check potential fake news stories on its platform, Fox criticized the fact-checkers for having “a liberal bias” and a “proven” bias “against conservatives.”