-30K. 74. Who is in law a “first or main publisher”? I turn then to the first of the central issues in this appeal: Are the respondents in law to be treated as the first or main publishers or merely as subordinate publishers of the defamatory statements posted by the forum users in question? What are the criteria for determining whether a person who plays some role in the process of publishing a particular article is a first or main publisher of that article? 75. As the authorities on the innocent dissemination defence show, in a newspaper setting, the journalist, editor, printers 61 and (vicariously) the newspaper proprietor are all treated as first or main publishers. In my view, this is because they are persons whose role in the publication process is such that they know or can be expected easily to find out the content of the articles being published and who are able to control that content, if necessary preventing the article’s publication. It is because they occupy such a position that the law has held them strictly liable for any defamatory statements published. 76. In my view, the abovementioned characteristics supply the criteria for identifying a person as a first or main publisher. They are (i) that he knows or can easily acquire knowledge of the content of the article being published (although not necessarily of its defamatory nature as a matter of law); and (ii) that he has a realistic ability to control publication of such content, in other words, editorial control involving the ability and opportunity to prevent publication of such content. I shall, for brevity refer to them as “the knowledge criterion” and “the control criterion” respectively. 61 Although they may nowadays better be viewed as subordinate publishers.