Kiefel Keane Gleeson CJ J J 6. 21 A focus on the intention of a putative publisher to communicate the matter complained of is also said to explain the cases concerning whether occupiers are publishers of defamatory statements affixed to their premises or structures by unauthorised third parties, the appellants contend. These cases hold that, to be a publisher, an occupier must have consented to, approved of, adopted or promoted the continued presence of the statements, such that it can be said the occupier accepted responsibility for their presence. The question of publication is therefore determined by the courts by drawing an inference that the occupier intends to communicate the matter, the appellants contend. No such deliberate act is present in these appeals which would permit an inference of intention on the part of the appellants to be drawn, it is submitted. 22 The appellants' contentions are not supported by authority and cannot be accepted. Publication and intention 23 In the law of defamation, harm is understood to be occasioned to a person's reputation when a defamatory publication is made to a third party. Publication is the actionable wrong. In Dow Jones & Co Inc v Gutnick18, publication was described as a bilateral act by which the publisher makes the defamatory material available and a third party has it available for their comprehension. Publication may therefore be understood as the process by which a defamatory statement or imputation is conveyed19. 24 In Trkulja v Google LLC20, it was said that "[i]n point of principle, the law as to publication is tolerably clear". The judgment of Isaacs J in Webb v Bloch21 was cited for that proposition. In that case, Isaacs J drew upon texts to identify who may be a publisher. Folkard22 described the word "published" as a technical term in the law of libel. It is used, he said: 18 (2002) 210 CLR 575 at 600 [26]. 19 Rolph, Defamation Law (2016) at 140 [8.20]. 20 (2018) 263 CLR 149 at 163 [39]. 21 (1928) 41 CLR 331 at 363-364. 22 Folkard, The Law of Slander and Libel, 5th ed (1891) at 439 (emphasis added by Isaacs J).