Carter v. B.C. Federation of Foster Parents Assn. Page 12 regime and discussed whether it would be appropriate to adopt new rules in light of this dramatic new development in publishing. Callinan J., in his concurring reasons in order to succeed it would have to persuade the court that it should depart from a line of authority beginning with the case of Duke of Brunswick v. Harmer, [1849] 14 Q.B. 185. He noted that the principle enunciated in Duke of Brunswick was also recently referred to with approval by the House of Lords in the case of Berezovsky v. Michaels, [2000] 1 W.L.R. 1004 (H.L.). At para. 197, Callinan J. observed, "[e]ach publication under current law gives rise to a separate cause of action. This is entrenched in Australian and English law". The court found that a single publication rule could only be introduced in Australia by statute. [18] Stated simply, the single publication rule is an American rule of law (adopted in many but not all states) under which several communications to a third party of a defamatory statement are held to be only one publication and the limitation period begins to run from the date of the first such communication: Firth v. State of New York, 775 N.E.2d 463 (Ct. App. 2002). Although it is difficult to find an express statement in the Canadian cases about the single publication rule, the clear tendency of the authorities in my view is in favour of the English and Australian position and not in favour of the American position. For instance, in the case of Lambert v. Roberts Drug Stores Ltd. (1933), 41 Man. R. 322 (C.A.), Trueman J.A. speaking for the court states at 324: It is elementary that every sale or delivery of a written or printed copy of a libel is a fresh publication, for which an action lies, unless the defendant can satisfy the jury that he was ignorant of its contents and 2005 BCCA 398 (CanLII) in that case, pointed out at para. 191 that the appellant publisher acknowledged that