In internet defamation cases, publication to unknown individuals may be inferred from evidence that the defamatory material appeared prominently in search engine results when searching for the plaintiff's or a related person's name, combined with the notoriety of the subject matter and the regularity of internet use, even where the direct evidence of search result prominence relates to periods outside the limitation period. An award of $150,000 including aggravated damages is within the appropriate range for grave defamatory imputations such as allegations of manslaughter, particularly where the defendant refused to apologise and persisted with untenable defences.
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