Nevertheless, he was still in financial difficulties, having lost most of his American investments in the Wall Street Crash. He was criticised for holidaying in the Riviera and America as the guest of such people as Beaverbrook and William Randolph Hearst, and for drinking and gambling with people such as Brendan Bracken and, until his early death, Lord Birkenhead. These attacks were not new; in 1923 Churchill had brought a successful libel action against Lord Alfred Douglas who had accused Churchill of giving a deliberately false account of the Battle of Jutland at the request of Sir Ernest Cassel. Douglas was sentenced to imprisonment for six months.