operating outside Hong Kong, and the contents in question are links to websites with descriptions of the Incident, without involving any actual legal proceedings, let alone any court order. c . In HKSAR v Wonÿ Tak Keuns, the respondent's approach, which was relied on by the Appellant, was held to be not applicable, not to mention the wholly different context of criminal territorial jurisdiction. There is a further significant distinction between those offences under the Ordinance which are substantive, and the offence of conspiracy in HKSAR v Wons Tak Keung which is inchoate. 63. In the circumstances, the Appellant has failed to point to any substantive and convincing materials both within and outside of the Ordinance to support his contention in relation to extra-territorial effect of the Ordinance. 64. The general principle that local legislation has no extra-territorial effect unless there are strong pointer to the contrary is a strong one. In the Ordinance itself there is nothing to suggest that the Ordinance would catch and apply its force to persons outside of Hong Kong in the context of privacy protection of data. 65. The Respondent submitted that the difficulty it has in taking enforcement action against a foreign entity and the fact that no provision appears in the Ordinance to deal with that matter mitigate against any extraterritorial effect of the Ordinance. That consideration is a strong indication against extra-territorial effect since it will be frivolous for the Respondent 50