MR JUSTICE WARBY Approved Judgment NT1 & NT2 v Google LLC (at [59]-[66]), and cannot be repeated here lest they serve to identify NT1. But it is fair to say that the Court accepted the trial Judge’s view of the roles of NT1 and Fitzgerald, and found that NT1 was the principal actor in the false accounting conspiracy, which had involved “the corruption of others”. The Court of Appeal, reducing Mr Fitzgerald’s sentence, found that he had been a young second-incommand to NT1. 77. The third URL complained of by NT1 takes one to an extract from a book (“the Book Extract”) first published some two years after the Court of Appeal decision. The Book Extract comprises a headline and 6 paragraphs of text. The content is similar to that of the First and Second Articles. 78. A recent Google search, a copy of which is in the papers, throws up a snippet from each of the First Article, the Second Article and the Book Extract. Snippets from the Articles appear as items one and two on the first page of the search. A snippet of the Book Extract is item eight on page two. The snippets are set out in the Private Judgment (at [67]-[68]). They were the subject of some submissions by Mr Tomlinson in closing, but as the pleaded complaint is one of inaccuracy in the underlying publications, not the snippets, I do not consider it would be right to assess the snippets. The complaints 79. Six complaints of inaccuracy are made. They are not all in the same form, but the commonest format adopted is to pick out some word(s) or phrase(s) from one or more of the three URLs complained of and assert baldly that “The claimant did not ‘[QUOTE WORD(S)/PHRASE(S)]’”. The pleaded case does not identify which of the URLs contains the alleged inaccuracy. No particulars of inaccuracy are provided. This is not especially transparent or helpful. It has required me to carry out an analysis of where the alleged inaccuracies are to be found. That analysis suggests that there are three complaints about the First Article, five about the Second Article (three of which relate to that article only), and two about the Book Extract. The claimant’s approach also seems to beg the question of what sense a given word or phrase bears, when read in its context. I cannot help feeling that in a context such as the present – where the claimant sues in respect of media publications – he should be expected to specify the meaning(s) he attributes to particular words or phrase, and which he says is inaccurate. A claimant should also give particulars of inaccuracy. Those are wellestablished requirements of a statement of case in a defamation or malicious falsehood claim, which are surely appropriate in this context for the same reasons. It is after all NT1 who alleges inaccuracy, and so the burden of proof rests on him, as Mr Tomlinson accepts. The right approach in principle 80. NT1’s case is that there have been breaches of the first part of the Fourth Principle: the requirement that personal data “shall be accurate”. The requirement that data be “kept up to date” does not have any application in this context. There has been some dispute about how to decide whether a published article is “inaccurate” for this purpose. Two sources of law have been addressed.

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