Actually, the last court decision...
I saw stated personal animus is unproveable unless the defendant personally knows the litigant. BUT...when vitriol is spewed against individual or group beliefs, or a singular/united action of same, said activity AND the injurious results of same is plainly actionable. When a commercial activity is the target, THAT'S when the punishment becomes very expensive and sentences much longer...due, of course, to the greater damage potential. Also, case law re;foreigners attacking U.S. business enterprises for personal gain is quite developed...contrary to popular myth.