Lee Hsien Loong v Leong Sze Hian [2021] SGHC 66 accessed the defamatory content. It is certainly arguable that, insofar as English courts have attracted defamation cases with little or no connection with England, possibly because of the attractiveness of English damages awards, Jameel is a response to these concerns. There is no suggestion that concerns of forum shopping apply on the instant facts. 70 The defendant suggests that the decision in Qingdao Bohai illustrates wholesale acceptance by the Singapore courts of the reasoning in Jameel. I decline to go so far, and make three observations on that case. First, Qingdao Bohai was precisely a case where there were at least some concerns of forum shopping. As the Court observed at [1] of Qingdao Bohai, that case concerned 12 articles posted on several foreign websites, and two articles containing similar content which were published in Taiwan on 29 November 2013 in two newspapers. The Court even went so far as to conclude that the first plaintiff in that case did not even have a reputation in Singapore at the material time: Qingdao Bohai at [49], [53], and [60]. Second, Jameel was, at best, a highly secondary basis for rejecting the plaintiff’s claim. Significantly, the plaintiff could not even establish that the first requirement for making out publication in the context of online defamation, namely that the defendant had uploaded or posted the defamatory material on the internet: at [121]. Jameel was thus not central to the reasoning of the Court in Qingdao Bohai. Third, and critically, the facts in Qingdao Bohai were somewhat extraordinary in that the Court concluded that only one single third party had accessed the allegedly defamatory material. This quite exceptional consideration is not reflected in, for example, the present case, where (a) several dozen individuals had directly interfaced or responded to the Post containing the linked Article (see [7] above); (b) the Post was published on the defendant’s Facebook Wall, and would have been flagged to his 5,000 Facebook friends and 149 Facebook followers; and (c) the Post was 38