requiring the plaintiff to prove that the defendant knew, or ought to have known, that the work contained the defamatory words or symbols. However, the defence of innocent dissemination may be established by showing both that participation in the publication is secondary and that the participant’s ignorance of the defamatory material was not negligent.” 127 His Honour also dealt with a series of first instance cases, in the UK, an example of which is Bunt v Tilley [2007] 1 WLR 1243; [2006] EWHC 407 (QB), which dealt with the liability (or, more accurately, the lack of liability) of Internet service providers (ISPs) through which individual defendants had made defamatory posts on webpages hosted by others. The Chief Justice distinguished such a situation from that which was then before the South Australian Supreme Court, with which distinction, with great respect, I agree. 128 Further, Kourakis CJ dealt with the concept of a “passive medium”, which was a description afforded an ISP by Eady J in Bunt, supra. However, Kourakis CJ referred to the concept as one that was likely to mislead, when referring to electronic media, because almost everything occurs by operation of one or other pre-programmed results or the application of a mathematical algorithm. 129 Nevertheless, his Honour the Chief Justice further distinguished, in terms that dealt with their approval of the process, persons who were administrators, webpage masters, providers and managers of Internet forums or web-based bulletin sites. In that passage, which is apposite to the discussion of the issues now before the Court, Kourakis CJ said: “[141] Webpage masters of internet forums or web-based bulletin sites which receive communications electronically but then make them readable in an organised manner by visitors to their webpages are in a very different position. Hosts of those webpages more closely facilitate the publication of material, on their sites because: • they invite communications on a particular subject matter (indeed, comment and discussion is the very purpose of such sites); • they have a greater capacity to read both by virtue of the form it is in and the more limited quantity of material they receive in comparison to the data for which telecommunications cable provider or an ISP is a conduit; and • they have a practical capacity to control the content of their website. [142] Accordingly, the hosts of webpages which invite discussion have been found to be publishers at common law in Godfrey v Demon Internet Limited,