由此 - 35 - A B C D (i) 131. Factor 8: Whether the article contained the gist of that person’s side of the story. It did not. Even the contents of ARY’s letter to the Washington Post were not properly presented. (j) D F 132. I have already dealt with this in Part III.A.1 of this Judgment. G H (k) I 133. Factor 10: The circumstances of the publication (including its timing). I have no observations to make on this factor. H I J J (l) Summary K K 134. M C Factor 9: The tone of the article. G L B E E F A An application of the factors all points one way. I do not accept that ATOL met the required standard of journalistic responsibility. It therefore had no duty to publish the Article in the public interest and L M cannot claim qualified privilege in relation to the Article. ATOL is thus N liable in defamation. O O B. Quantum B.1 Whether general damages P Q N 135. Mr. Carolan asks for damages of $1 million in relation to each R P Q R of ARY and Digital UK and $300,000 in relation to ARY Traders. S S T T U U V V