Will Conrad Black come after Tom Bower?

Ian Burrell in the Independent today suggests that former Telegraph owner Conrad Black, soon to be freed on bail in the US, may be returning to court in the UK - to sue biographer Tom Bower.
Burrell claims Lord Black will want to return to the UK: "Not least because he wishes to take legal action against the author Tom Bower, who documented his downfall in Conrad and Lady Black, a waspish account published by Harper Collins, owned by the rival media baron Rupert Murdoch. The book was sold as a story of 'ambition and greed ... a modern-day classic of hubris'. In an article penned from his prison cell and published by Tatler in 2007, Lord Black claimed that the book plumbs profound depths of libel and prosaic clumsiness'.
"Bower would certainly contest any claim, having already successfully seen off a libel action brought over the same book by another media baron, Richard Desmond, who complained that Bower had demeaned him by saying that Lord Black had "ground into the dust" the owner of Express Newspapers."