colleagues. If the possibility of direct recognition is required, the first propagator may not be punished as the requirement that many or unspecified persons can directly recognize is not satisfied at any stage in the case as constructed above. However, it is identical in that the general risk that the social estimation of the victim can be infringed is caused in comparison to the case where the first propagator simultaneously sends an e-mail or a text message to many persons from the outset. 3) The Dissenting Opinion criticizes that the Supreme Court precedents have recognized publicity on the grounds of propagation possibility even though publicity cannot be admitted in the case of conversations in a personal relationship in light of the purpose of requiring publicity as a constituent element in criminal defamation. However, Supreme Court Decisions 68Do1569, 85Do431, etc., which are mentioned in the Dissenting Opinion, are not cases that can be regarded as private conversations merely conveying information in personal relationships or naturally occurring in everyday life. In other words, they represent cases where even if the other party is a friend or colleague, the other party of the alleged facts is not in relationships close enough not to let the outside world know the alleged facts with the criminal defendant or the victim (for instance, it may be a colleague who does not usually have specific interactions or a friend out of contact for ten years), there is high possibility to be propagated in light of the details or manner of the alleged facts, and the victim’s reputation is seriously endangered in being defamed as a result thereof. The standards for determining publicity which the precedents of the Supreme Court have accumulated is to consider the overall circumstances as above, and the legal principle on limitation as mentioned in the Majority Opinion also is formulated to develop them. Accordingly, cases as above cannot be readily concluded as simple conversations held in personal relationships, and schematizing as if the theory of propagation possibility is designed to punish private conversations proceeds from a false premise or misconception of the theory of propagation possibility. Furthermore, excluding them from the subject of punishment on the grounds of personal relationships is unreasonable, considering that the boundary between private and public relationships becomes blurred and undermined as the development of information and communications networks and virtual human exchanges increase as above. D. As mentioned in the Dissenting Opinion, even if publicity is understood as a state that many or unspecified persons can directly recognize, the case where facts were