-39publisher if, having relevant knowledge or easy access to knowledge and editorial control so as to be able to prevent publication of defamatory content, he fails to exercise such control. The subordinate publisher who, in contrast, forthwith takes all reasonable steps to prevent further publication, should not be placed in the same category. Whether in any particular case the subordinate publisher succeeds in proving that he has met those requirements is again a question of fact. Evidence as to how readily the offending content could be withdrawn or deleted would be important. 98. I note in this context that in Metropolitan International Schools Ltd v Designtechnica Corpn, 79 Eady J considers the position after defamatory content is brought to the attention of a search engine operator and points out that: “There is a degree of international recognition that the operators of search engines should put in place such a system (which could obviously either be on a voluntary basis or put upon a statutory footing) to take account of legitimate complaints about legally objectionable material.”80 99. His Lordship suggests that : “...it does not follow as a matter of law that between notification and ‘take down’ the third defendant becomes or remains liable as a publisher of the offending material. While efforts are being made to achieve a ‘take down’ in relation a particular URL, it is hardly possible to fix the third defendant with liability on the basis of authorisation, approval or acquiescence.”81 M. 100. The defence of innocent dissemination applied to the respondents We are only concerned with the 2008 and 2009 statements. It is not in dispute that the respondents were unaware of the postings containing those statements until the 2008 statements were subsequently brought to their attention by the appellants and until they themselves discovered the 2009 79 [2011] 1 WLR 1743 at §54. 80 At §56. 81 At §58.