Case 0:17-cv-60426-UU Document 169 Entered on FLSD Docket 06/04/2018 Page 17 of 22 Rather, it is the hyperlinked CNN article that describes the confidential briefings and asserts that the FBI is investigating the truth of the Dossier’s allegations. The question then is: would an ordinary reader of the Article conclude that the Dossier was subject to these official actions when these official actions are mentioned only in the hyperlinked CNN article? The Supreme Court of Nevada is the only court to confront this question. In Adelson v. Harris, the Second Circuit certified the question to the Nevada Supreme Court, which held that a hyperlink renders a report privileged provided the hyperlink is conspicuous. 402 P.3d 665 (Nev. 2017). The court reasoned that “the hyperlink is the twenty-first century equivalent of the footnote for purposes of attribution in defamation law, because it has become a well-recognized means for an author or the Internet to attribute a source and the hyperlink instantaneously permits the reader to verify an electronic article’s claims.” Id. at 669 (internal quotations omitted) (citing Adelson v. Harris, 973 F. Supp. 2d 467, 484 (S.D.N.Y. 2013), aff’d, 876 F.3d 413 (2d Cir. 2017)). Adelson is aligned with modern journalistic principles and the way information is consumed in the digital age. See, e.g., Michael Schudson, et al., Link Think: News organizations and their hyperlinking choices, Columbia Journalism Review, March/April 2012, https://archives.cjr.org/the_research_report/link_think.php (“Publishing such heavily linked features holds reporters accountable by requiring them to show the sources of their work. It also helps readers find more information or deepen their research, if they want to.”); Daniel Luzer, Linked Out: One day, one story, one million hyperlinks, Columbia Journalism Review, December 3, 2008, https://archives.cjr.org/overload/linked_out.php (“[T]he hyperlink is the building block of this democratization of information.”); Mark Sableman, Link Law Revisited: Internet Linking Law at Five Years, 16 Berkeley Tech. L.J. 1273, 1276 (2001) (“Hypertext links 17