A defendant invoking the Lange qualified privilege defence must expressly plead reasonableness of conduct as an element of the defence; alternatively, if relying on common law qualified privilege for political communications, the defendant must plead the material facts establishing the relevant duty and corresponding interest. A bare plea that a communication constituted dissemination of information on a government or political matter is insufficient for either form of the defence. Separate files on a website, even if linked, may be treated as separate publications for defamation purposes where each has its own substantive identity and purpose, though this may depend on evidence about how the content is accessed and presented.
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