MR JUSTICE WARBY Approved Judgment 69. Monroe v Hopkins [2017] EWHC 433 (QB) Where an allegation has a seriously defamatory tendency and is widely published a claimant may choose to rely on those facts alone, perhaps in conjunction with evidence as to the identity of the publishees, as the basis for an inference that serious harm was actually caused. That, at one stage at least, was the primary position adopted on behalf of Ms Monroe. In some cases it may be enough. It is certainly not necessary in every case to engage in a detailed forensic examination of the precise factual picture, in order to determine whether the Serious Harm requirement is satisfied. Often, the factors relevant whether serious harm has been caused will be “the same as those which come into play when assessing whether a tort is real and substantial for Jameel purposes” or an abuse of process: Ames v Spamhaus Project Ltd [2015] EWHC 127 (QB), [2015] 1 WLR 3409 [52].2 As pointed out by HHJ Moloney QC (sitting as a Judge of the High Court) in Theedom v Nourish Training Ltd [2015] EWHC 3769 (QB) [2016] EMLR 10 [15](h). "it is important to bear in mind that s 1 is essentially a threshold requirement, intended by Parliament to weed out those undeserving libel claims otherwise technically viable, but which do not involve actual serious harm to reputation or likely serious harm to reputation in the future." 70. In this case, however, the issues on serious harm have developed, and the evidence and argument has spawned a reasonably complex set of interlocking or overlapping sub-issues. This is mainly due to the way that the case for Ms Hopkins has been pleaded and pursued. There are no less than 11 main issues. I have reached the clear conclusion that the Serious Harm requirement is satisfied, on the straightforward basis that the tweets complained of have a tendency to cause harm to this claimant’s reputation in the eyes of third parties, of a kind that would be serious for her. In the light of that conclusion I do not believe it is necessary for present purposes to examine in exhaustive detail all the sub-issues. Nor do I think it necessary for the purposes of arriving at a fair and reasonable conclusion on the extent of harm, and the appropriate sum in damages. I therefore do not think that I do an injustice to the considerable skill and effort that has been devoted to these issues if I identify and address them in turn, in fairly summary form. 71. The main points, and my conclusions on them, are these:(1) The extent of publication. Reliance is placed on the allegedly limited extent of publication of the First Tweet, and its deletion “around two hours” after first publication. I have dealt with and rejected Ms Hopkins’ case on these points. (2) Transience. It is true that the First Tweet was transient. The Second Tweet less so, although any tweet disappears from the reader’s view as time goes on. But this is a weak point. What matters, when considering transience, is not the period of time for which a person is exposed to the message but the impact the message has. It is a commonplace of experience that live broadcasts can have a powerful impact, even if the viewer sees them once only. Print copies of newspapers are not often read more than once. 2 Jameel v Dow Jones & Co. Inc. [2005] EWCA Civ 75, [2005] QB 946