Kiefel CJ Bell J Keane J Nettle J Gordon J 15. 40 The Court of Appeal were also incorrect to say50 that it was incumbent on Mr Trkulja to plead that Google is a primary or secondary publisher of the allegedly defamatory matters. It is not the practice to plead the degree of participation in the publication of defamatory matters51, for the reason that all degrees of participation in the publication are publication. As Isaacs J held in Webb v Bloch52: "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." 41 If Google wishes to invoke the defence afforded to "subordinate distributors" by s 32 of the Defamation Act or otherwise contend that the degree of its participation in the publication of the impugned search results was such that it should not be held liable, it is for Google to plead and prove the relevant facts. (ii) Capacity to defame 42 The Court of Appeal's process of reasoning as to the capacity of the impugned web searches to defame Mr Trkulja proceeded from dual premises that whether "any of the defamatory imputations which are pleaded [are] arguably conveyed" is to be determined by reference to the understanding of "an ordinary reasonable user of a search engine such as the Google search engine, without which the facility to navigate the trillions of pages on the world wide web would be gravely compromised", and having regard to the "entirety of the matter relied upon"53. 50 Google Inc v Trkulja (2016) 342 ALR 504 at 557 [225]. 51 See Mullis et al (eds), Gatley on Libel and Slander, 12th ed (2013) at 984-986 [26.5], 1398-1408 [A1.6]-[A1.11]; Blair et al (eds), Bullen & Leake & Jacob's Precedents of Pleadings, 17th ed (2012), vol 1 at 634 [37-08]; Tobin and Sexton (eds), Australian Defamation Law and Practice, looseleaf, service 72, vol 1 at [25,075]-[25,090]. 52 (1928) 41 CLR 331 at 363-364 quoting Folkard, The Law of Slander and Libel, 5th ed (1891) at 439 (second and third emphasis added by Isaacs J). 53 Google Inc v Trkulja (2016) 342 ALR 504 at 597 [388]-[390].