An internet search engine operator becomes a publisher of defamatory search result snippets and a republisher of the underlying defamatory webpages after receiving notification of the defamatory content and failing to remove it within a reasonable time. The automated nature of the search engine's processes does not preclude a finding of publication where the operator has knowledge and the capacity to prevent continued publication. Google's Autocomplete utility can constitute a separate publication of defamatory material. The defence of innocent dissemination under s 30 of the Defamation Act 2005 (SA) is not available to a search engine operator that has been notified of defamatory content and failed to remove it.
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