-1022. Moreover, publication could (and still can) be established against a person who is vicariously liable for his servants’ acts of publication or for acts of publication which he has authorised. All who participated directly or vicariously in the publication were held jointly and severally liable for the entire damage suffered by the plaintiff, regardless of the degree of responsibility each had for the publication. As Gatley points out: “The person who first spoke or composed the defamatory matter (the originator) is of course liable, provided he intended to publish it or failed to take reasonable care to prevent its publication. However, at common law liability extends to any person who participated in, secured or authorised the publication (even the printer of a defamatory work) though this is qualified by [the common law defence of innocent dissemination]...”18 “In accordance with general principle, all persons who procure or participate in the publication of a libel, and who are liable therefor, are jointly and severally liable for the whole damage suffered by the claimant.”19 23. Thus, under the strict rule, publication of a libel, for instance by a newspaper, meant that the journalist who was the originator of the article; the editor who accepted and prepared it for publication; the printer who set the type and printed it; the wholesale distributor who disseminated it; the newsagents who sold it to the readers; and the newspaper’s proprietor who published it through its employees or agents were all jointly and severally liable for the damage to the plaintiff’s reputation. D. The common law defence of innocent dissemination 24. The strictness of the publication rule plainly called for some relaxation. The common law defence of innocent dissemination was developed to that end. It was a defence which became established in English law as a 18 At §6.4. 19 At §6.5, footnotes omitted.