Lee Hsien Loong v Leong Sze Hian [2021] SGHC 66 without more, that there had been publication to the extent which the plaintiff asserted. Rather, the evidence, including that elicited through crossexamination, needs to be considered holistically. 105 In the circumstances, therefore, I find that the extent of the publication of the Post (which I refer to in this context as incorporating the Article: see above at [42]), would have been at most about 400 persons to whom the defamatory words had been published. I emphasise that this figure refers specifically to (a) users who were based in Singapore, (b) users to whom the defamatory words had been published, meaning that they must have received the information in such a way that it was understood (Qingdao Bohai at [35]), and (c) users who received the information through, whether directly or indirectly, the defendant’s acts. 106 How this figure of 400 is reached is as follows: At the very least, there were 22 reactions, 5 comments, and 18 shares. The Post thus must have been published to at least these 45 individuals, though it is unclear if all of them were in Singapore, and it is further unclear whether the same person(s) may have liked and shared the same post. Accounting for the defendant’s friends and followers on Facebook, there were at least about 5,000 such Facebook users, though again it is unclear (a) whether all of the accounts in that figure are based out of Singapore, and (b) whether they would all have seen the Post on their Facebook Newsfeeds in an intelligible form. The plaintiff indicates that about 2,060 of the defendant’s 5,000 Facebook friends and followers are based in Singapore, and Dr Phan estimates that 10 to 20% of this figure would have accessed the Post in an intelligible form. These figures of 10 to 20% are 200 to 400 users, and the figure of 400 is reached accordingly. 57

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