Lee Hsien Loong v Leong Sze Hian [2021] SGHC 66 a minimum of 22 users initially accessing the Post and reacting to/commenting on/sharing the Post, and (b) each of those 22 users having an average of 300 friends on Facebook, the Post would have appeared on the Facebook “news feeds” of up to 6,600 users.45 This was predicated on the assumption that the 6,600 users had logged in to Facebook during the time the Post was available on the defendant’s Facebook timeline. Dr Phan suggested that the actual number might be considerably higher than 6,600 users given the possibility that those 6,600 users may have themselves shared the Post. 98 I note, however, that there is a distinction to be drawn between individuals on whose Facebook news feeds the Post might have appeared, and individuals who actually were online at the relevant times and accessed the Post. After all, Facebook news feeds continue to update based on the actions of one’s Facebook friends, and the mere fact of a post potentially appearing at some point on one’s news feed cannot be taken, without more, to mean that the post was accessed by that particular user. Moreover, there is no suggestion that the 6,600 users referred to above were all from Singapore. 99 In relation to my latter concern, Dr Phan’s view was that the minimum number that would have accessed or downloaded the Post would have been 200 to 400, on the basis that 10 to 20% of the defendant’s 2,060 friends and followers and followers based in Singapore had done so.46 When queried further on this figure, Dr Phan indicated that these 10 and 20% estimates were “well below one standard deviation, almost two standard deviations below [that] 45 2 BA 407 at [46] and [47]. 46 2 BA 408 and 409. 54