The issue is probably more to do with how injury is defined in the context of defamation law. Actual damages require that they prove the victim lost something t

The issue is probably more to do with how injury is defined in the context of defamation law. Actual damages require that they prove the victim lost something tangible as a direct result of the defamation. It's not hard to argue that he lost out on the grant funding due to the previous leak or some other outside factor. The decision is more like saying the original article was a marginal factor in the specific claim they made in the lawsuit but the egregiousness of the defamation was severe enough to warrant further damages.