late to deny that focus of the law. Yet, it is the publication of the material, not its composition, which is the actionable wrong: Lee v Wilson, supra, at 287, per Dixon J (as his Honour then was), cited with approval in Gutnick, at [25]. 99 In the words of the plurality in Gutnick: “Harm to reputation is done when a defamatory publication is comprehended by the reader, the listener, or the observer. Until then, no harm is done by it. This being so it would be wrong to treat publication as if it were a unilateral act on the part of the publisher alone. It is not. It is a bilateral act – in which the publisher makes it available and a third party has it available for his or her comprehension.” (Gutnick, at [26]) 100 The High Court, in the reasons for judgment of the plurality (Gleeson CJ, McHugh, Gummow and Hayne JJ) then discussed the consequential “bilateral nature of publication” and, as a consequence, raised the question as to where the tort of defamation is committed, in circumstances where the publisher acts in one place and presents the defamatory material in a comprehensible form in another place, and each place is a different jurisdiction. The judgment also deals with the single publication rule and its effect on the answer to the proper jurisdiction for the cause of action. It is unnecessary to deal with that issue. 101 Their Honours, in the plurality judgment, then discuss the effect, if any, of the technological change associated with the Internet and the World Wide Web. The Court determined that, in principle, the same issues as to dissemination on a broad basis have arisen in the past with mass circulation newspapers and radio and television broadcasts. The Court concluded: “However broad may be the reach of any particular means of communication, those who make information accessible by a particular method do so knowing of the reach that their information may have. In particular, those who post information on the World Wide Web do so knowing that the information they make available is available to all and sundry without any geographic restriction.” (Gutnick, at [39].) 102 Ultimately, the Court determined that, ordinarily, an action for defamation, based as it is on the location of the place where the damage to reputation occurs, will occur where the defamatory material is available in comprehensible form, assuming, in that respect, that the person defamed has a reputation in that place. 103 As a consequence of the principles to which the High Court refers in Gutnick, it is the publication of the material in comprehensible form in a location where