separated an issue out for a separate question, in accordance with the Uniform Civil Procedure Rules 2005 (NSW) (hereinafter “UCPR”), no question or questions had been prescribed for answer. 4 At the outset of the proceedings, an issue arose as to the question for the Court and, in particular, whether the question intended to be separated by the Court, in its earlier directions, included the Court dealing with the defence of Innocent Dissemination: s 32 of the Defamation Act 2005 (NSW). The terms of s 32 of the Defamation Act assume that “innocent dissemination” is a “defence” to the “publication of defamatory matter” and, in that regard, assumes that the innocent disseminator has published. This will be dealt with more fully later in these reasons. 5 Nevertheless, the parties, after short openings, were referred into conference to agree on the question to be asked of the Court. That agreed question is: “Whether the plaintiff has established the publication element of the cause of action of defamation against the defendant in respect of each of the Facebook comments by third-party users that are alleged to be defamatory?” 6 To answer the foregoing question, it is unnecessary to determine, presently, whether the material on the public Facebook page is defamatory or whether defences exist that would exonerate the defendants or ameliorate the damages caused by the defendants, were they found to be liable. As stated, the defendants sought, at least initially, to have the issue of “innocent dissemination” answered, but agreed to the question above, perhaps on the basis, to which some authorities refer, that an “innocent disseminator” is not a publisher. 7 The question on which the parties agreed does not seem, directly, to raise whether the defence of “innocent dissemination”, arising under s 32 of the Defamation Act, is available. Nevertheless, there are certain aspects of the process by which the comments of third parties are placed, or remain, on the public Facebook page of the defendants that directly raises this aspect. Facts and Evidence 8 The facts relevant to the allegedly defamatory material have probably been sufficiently outlined to enable an understanding of the issue before the Court. Each of the media companies that is the defendant in each of the proceedings