Kiefel Keane Gleeson CJ J J 3. 10 Provisions of the Act refer to the "publication of defamatory matter" 4. "Matter" is relevantly defined5 to include an article, report or other thing communicated by means of a newspaper and a report or other thing communicated by means of television, the internet or any other form of electronic communication. The Act does not define what is meant by the "publication" of defamatory matter. Resort is necessary to the general law in that regard. 11 The Defamation Act makes provision, in s 32, for a defence of innocent dissemination. A defence of this kind has its origins in the common law. No question as to the availability of the statutory defence arises with respect to the answer to the separate question. Nevertheless, the appellants refer to the cases which developed the defence at common law and later observations about those cases. The appellants submit that the cases illuminate what it means to be a publisher. The argument and decision below 12 The appellants argued their cases in the Court of Appeal on the basis that, to be publishers, they must have been instrumental to, or a participant in, the communication of the alleged defamatory matter. This was a correct approach and followed the meaning of publication given in Webb v Bloch6, to which reference is made later in these reasons. 13 The appellants argued that they did not make the defamatory comments available to the public, did not participate in their publication and were not in any relevant sense instrumental in their publication7; they merely administered a public Facebook page on which third parties published material. They submitted to the Court of Appeal that they were more closely equivalent to the supplier of paper to a newspaper owner or the supplier of a computer to an author. 14 Reliance was also placed by the appellants on cases which involved actions brought against owners or occupiers of premises in which unauthorised third 4 See, for example, s 8, s 32. 5 s 4. 6 (1928) 41 CLR 331 at 363-364. 7 Fairfax Media Publications Pty Ltd v Voller (2020) 380 ALR 700 at 712 [45].