-36for their dissemination, but the respondents were not aware of their content and realistically, in a many-to-many context, did not have the ability or opportunity to prevent their dissemination, having learned of them only after they had already been published by their originators. The respondents are therefore in principle able to invoke the innocent dissemination defence as subordinate publishers. I deal in the next Section with the consequences of their acquiring knowledge of the defamatory content as such subordinate publishers. L. Reasonable care and subsequently acquired knowledge 90. Formulated as a defence which requires the defendant to prove that he did not know and would not, with the exercise of reasonable care in the relevant circumstances, have known that the article contained defamatory content, the focus of the innocent dissemination defence has been on past, completed publications. Thus, a newsagent who has already sold its consignment of newspapers which contained an offending article will rely on the defence seeking to prove that, when making the sales, it was not aware of the defamatory content and could not, with reasonable care, have discovered it. 91. What is needed to satisfy the standard of reasonable care will vary according to the circumstances. Thus, in an internet context, the standard may well demand particular monitoring of postings by certain forum members or of postings on particular discussion topics if previous experience indicates a propensity or special risk of defamatory postings. 92. The potential need for particular care in certain cases is illustrated by two decisions involving defendants who mounted campaigns against targeted persons. Thus, in Kaplan v Go Daddy Group,76 a customer dissatisfied with his Hunter Holden car started a blog website provocatively called “www.hunterholdensucks.com” inviting others to share their comments about 76 [2005] NSWSC 636.