Whatcott, 2013 SCC 11, [2013] 1 S.C.R. 467, at para. 32; R. v. Khawaja, 2012 SCC [2018] 3 S.C.R. 374, at para. 26; R. v. Sharpe, 2001 SCC 2, [2001] 1 S.C.R. 45, at para. 104; Canadian Newspapers Co. v. Canada (Attorney General), [1988] 2 S.C.R. 122, at p. 133). As McLachlin J., dissenting, but not on this point, explained in R. v. Keegstra, [1990] 3 S.C.R. 697, at p. 850: A second characteristic peculiar to freedom of expression is that limitations on expression tend to have an effect on expression other than that which is their target. In the United States this is referred to as the chilling effect. Unless the limitation is drafted with great precision, there will always be doubt about whether a particular form of expression offends the prohibition. . . . The result of a failure to [define any limitation with precision] may be to deter not only the expression which the prohibition was aimed at, but legitimate expression. The law-abiding citizen who does not wish to run afoul of the law will decide not to take the chance in a doubtful case. Creativity and the beneficial exchange of ideas will be adversely affected. [76] In the civil context, courts have taken care to circumscribe the tort of defamation to avoid causing a chilling effect on legitimate expression, in line with the goals of anti-SLAPP legislation (see Bent, at para. 165, per Côté J., and at para. 262, per Abella J.). As the intervener the Centre for Free Expression points out, since Pointes and Bent were released, the chilling effect on public debate has only been considered by courts under the weighing exercise to assess the concern that allowing the proceeding to continue will chill the expression of the defendant and others who might be sued in defamation (see, e.g., Schwartz & Red Lake Outfitters v. Collette, 2020 ONSC 6580, at para. 123 (CanLII); Catalyst Capital Group Inc. v. West Face Capital 2023 SCC 14 (CanLII) 69, [2012] 3 S.C.R. 555, at para. 79; R. v. Vice Media Canada Inc., 2018 SCC 53,