Lee Hsien Loong v Leong Sze Hian [2021] SGHC 66 the next issue is whether the second requirement, that a third party has accessed the defamatory material in an intelligible form, is met.22 45 On the basis of what has been described as a “platform of facts”, there is at least a prima facie case that the Article had been accessed through the link in the Post in an intelligible form. In Koh Sin Chong Freddie v Chan Cheng Wah Bernard and others and another appeal [2013] 4 SLR 629 (“Koh Sin Chong Freddie”) at [43] and [44], the Court of Appeal accepted that a platform of facts could be established from which the Court could properly infer that substantial publication had taken place. Some of the considerations which might form the basis for this platform of facts are as follows: (a) First, the number of “likes”, “shares”, “reactions” and comments which a post draws might provide insight into the number of individuals who accessed it, especially since not every individual who reads the post will necessarily respond in such a fashion: Bolton v Stoltenberg [2018] NSWSC 1518 at [154] and [155], as upheld in Stoltenberg v Bolton; Loder v Bolton [2020] NSWCA 45 at [102]; (b) Second, the number of “friends” and “followers” the poster has on the relevant social media platform is also relevant in determining whether or not substantial publication has taken place: Pritchard v Van Nes [2016] BCJ No. 781 at [83]; (c) Third, setting the privacy settings of the relevant post to “public” is also more likely to give rise to an inference that the defamatory statement had been accessed by third parties and that substantial publication arose: Doris Chia, Defamation: Principles and Procedure in 22 DCS at [2(a)]. 24