-9article in question contained those words. 13 Thus, a textbook published in 189114 stated: “The term published is the proper and technical term to be used in the case of libel, without reference to the precise degree in which the defendant has been instrumental to such publication; since, if he has intentionally lent his assistance to its existence for the purpose of being published, his instrumentality is evidence to show a publication by him.” 20. As Abella J pointed out in Crookes v Newton:15 “... the breadth of activity captured by the traditional publication rule is vast. In R v Clerk (1728), 1 Barn KB 304, 94 ER 207, for example, a printer’s servant, whose only role in an act of publication was to ‘clap down’ the printing press, was found responsible for the libels contained in that publication, despite the fact that he was not aware of the contents (p 207).” 21. While (as in the 1891 text) the traditional rule is sometimes expressed as requiring the publication to a third person to be “intentional”,16 that reference is generally directed at situations where the defendant who authored the defamation does not intend its publication to a third person but where publication takes place without negligence on his part. Thus, where a defendant’s private diary containing defamatory imputations is lost without negligence on his part and made public by another person or, to take an example given by Lord Esher MR, where “the writer of a letter locks it up in his own desk, and a thief comes and breaks open the desk and takes away the letter and makes it contents known...,”17 no intentional publication by the author occurs. The requirement of intention in this sense did not narrow the width nor dilute the strictness of the traditional rule. 13 Vizetelly v Mudie’s Select Library [1900] 2 QB 170 at 179; Godfrey v Demon Internet Ltd [2001] QB 201 at 207 per Morland J; Dow Jones & Co Inc v Gutnick (2002) 210 CLR 575 at §25. 14 Folkard on Slander and Libel, 5th ed (1891), at p 439, cited by Isaacs J in Webb v Bloch (1928) 41 CLR 331 at 363-364. 15 [2011] 3 SCR 269 at §18. 16 Gatley, at §§6.4, 6.10-6.11. 17 Pullman v Walter Hill & Co [1891] 1 QB 524 at 527.