-1330. As Gaudron J pointed out in Thompson v Australian Capital TV Ltd,26 the defence has been adopted not only in subsequent English cases, but also in Canada, Australia and New Zealand. In some jurisdictions, statutory defences along the same lines have been enacted. Thus in England, Lord McKay of Clashfern LC introducing the bill which became section 1 of the Defamation Act 1996, described it as “a modern equivalent of the common law defence of innocent dissemination”. 27 Hong Kong has not introduced such legislation and the defence which concerns us is that which exists at common law. 31. Although in both Emmens and Vizetelly, 28 it was suggested that successful invocation of the innocent dissemination defence leads to the defendant being deemed not to have published the libel at all, I respectfully consider the better view to be that stated by Duncan and Neill in an earlier edition of their work,29 noted by Brennan CJ, Dawson and Toohey JJ in their joint judgment in Thompson v Australian Capital TV Ltd,30 namely, that: “... it would be more accurate to say that any disseminator of a libel publishes the libel but, if he can establish the defence of innocent dissemination, he will not be responsible for that publication.” 26 (1996) 186 CLR 574 at 592. 27 See Godfrey v Demon Internet Ltd [2001] QB 201 at 204. Section 1(1) of the 1996 Act provides: “(1) In defamation proceedings a person has a defence if he shows that--(a) he was not the author, editor or publisher of the statement complained of, (b) he took reasonable care in relation to its publication, and (c) he did not know, and had no reason to believe, that what he did caused or contributed to the publication of a defamatory statement.” 28 Adopted in McPhersons Ltd v Hickie (unreported) No. 40290 of 1994 Supreme Court of New South Wales Court of Appeal, p 6 per Powell JA; and in the recent English Court of Appeal decision in Tamiz v Google Inc [2013] EMLR 14 at §§26-36, per Richards LJ. 29 Duncan and Neill on Defamation, 2nd Ed, 1983, p 110, fn 3. The discussion in the current edition focusses on the statutory defence provided by section 1 of the Defamation Act 1996. 30 (1996) 186 CLR 574 at 586.