40 The Administrators of Fairfax post approximately 50 comments a day and, albeit as an estimate, each post can receive anywhere from 100 comments to thousands of comments, which can be posted at any time during the day or night. Further, the use of sub-threads of comments renders the monitoring of all comments even more difficult, particularly because any comment, whether on a sub-thread or otherwise, may be posted many days after the initial post by the Administrator. 41 Ms Phan testified that if she were ever in a position where she viewed a comment which she thought was, or was reasonably likely to be, illegal, an infringement of third party intellectual property rights, grossly offensive, or otherwise an infringement of Fairfax’s agreement with Facebook, she would take action, immediately, by hiding the post or deleting the relevant comment and, possibly, blocking the user who posted it. Which of those three actions would be taken would depend upon the nature of the concern raised. Ms Phan testified that she hides and/or deletes comments on a regular basis. 42 Ms Phan commented on the Shelley Report and noted that: if words are moderated, the moderated post will still be able to be viewed by the person making the post and that person’s Facebook friends; users may substitute letters for numbers thereby invalidating any moderation, e.g., the plaintiff’s surname, “Voller” could be written as “Voll3r”; there are too many words in the English language to include given that there is a 10,000 character limit imposed by Facebook on moderated comments; and users could “share” a post to their own wall and thereby publish it. 43 Apart from the last mentioned comment, all of the others were comments made by Mr Shelley, either in his report or in his oral evidence. The last mentioned comment or aspect does not seem to be particularly relevant. If a person “shared” a post from the Sydney Morning Herald Facebook page, it would be the person who shared the post that would be “publishing” it to those persons who gained access as a consequence of the sharing. 44 The evidence in chief of Ms Ryan was in or to the same effect as that of Ms Phan, the necessary changes being made as to the identity of the owner of the public Facebook page, being Nationwide News Pty Ltd. Ms Ryan is the