Kiefel CJ Bell J Keane J Nettle J Gordon J 4. (b) The plaintiff is a hardened and serious criminal in Melbourne in the same league as convicted murderer Carl Williams, hardened notorious underworld killer Andrew 'Benji' Veniamin, hardened and serious and notorious murderer Tony Mokbel and the Mafia Boss Mario Rocco Condello[;] (c) The plaintiff is an associate of underworld killer Andrew 'Benji' Veniamin[;] [(d)] The plaintiff is an associate of Carl Williams Melbourne notorious convicted criminal murderer and drug trafficker; (e) The plaintiff is an associate of Tony Mokbel, the Australian notorious convicted murderer and drug supplier and trafficker; (f) The plaintiff is such a significant figure in the Melbourne criminal underworld that events involving him are recorded on a website that chronicles crime in [the] Melbourne criminal underworld[.]" 14 In the alternative it is contended that the images matter is defamatory in its true innuendo for carrying substantially the same imputations, and also that the gist of the images matter and the web matter is to associate Mr Trkulja with organised criminal activity in Melbourne. 15 The pleading then alleges that on or about 3 December 2012 Mr Trkulja sent a letter each to Google and Google Australia Pty Ltd ("Google Australia") (which at one time was the second defendant to the proceedings) by registered post drawing the allegedly defamatory matter to their attention, informing them of the nature of the defamatory matter, demanding that Google and Google Australia remove the images matter from their computers and servers, or to remove all links or direction from their computers and servers linking or directing internet users to the matter, requesting them to provide details including contact details of the source or sources of the matter, and demanding that they "block the name of Milorad Trkulja and Michael Trkulja from [their] computers and servers links or directing internet users to the name of 'Milorad Trkulja' and 'Michael Trkulja'". 16 On 14 December 2012, Google Australia responded to the effect that the "search products" to which Mr Trkulja's "inquiry" related were owned by Google and that Google Australia was "unable to further assist" him with his inquiry. Then, on 18 December 2012, Google sent an email to Mr Trkulja to the effect that Google Australia had forwarded Mr Trkulja's letter to Google; that the