legislation in other countries European Union Directive 2000/31/EC, the e-Commerce Directive, establishes a safe harbor regime for hosting providers: Article 14 establishes that hosting providers are not responsible for the content they host as long as (1) the acts in question are neutral intermediary acts of a mere technical, automatic and passive capacity; (2) they are not informed of its illegal character, and (3) they act promptly to remove or disable access to the material when informed of it. Article 15 precludes member states from imposing general obligations to monitor hosted content for potential illegal activities. The updated Directive on Copyright in the Digital Single Market (Directive 2019/790) Article 17 makes providers liable if they fail to take "effective and proportionate measures" to prevent users from uploading certain copyright violations and do not respond immediately to takedown requests. Australia In Dow Jones & Company Inc v Gutnick, the High Court of Australia treated defamatory material on a server outside Australia as having been published in Australia when it is downloaded or read by someone in Australia. Gorton v Australian Broadcasting Commission & Anor (1973) 1 ACTR 6 Under the Defamation Act 2005 (NSW), s 32, a defence to defamation is that the defendant neither knew, nor ought reasonably to have known of the defamation, and the lack of knowledge was not due to the defendant's negligence. Italy The Electronic Commerce Directive 2000 (e-Commerce Directive) has been implemented in Italy by means of Legislative Decree no. 70 of 2003. The provisions provided by Italy are substantially in line with those provided at the EU level. However, at the beginning, the Italian case-law had drawn a line between so-called "active" hosting providers and "passive" Internet Service Providers, arguing that "active" Internet Service Providers would not benefit from the liability exception provided by Legislative Decree no. 70. According to that case-law, an ISP is deemed to be active whenever it carries out operations on the content provided by the user, such as in case it modifies the content or makes any enrichment of the content. Under certain cases, courts have held ISPs liable for the user's content for the mere facts that such content was somehow organised or enriched by the ISP (e.g. by organizing the contents in libraries or categories, etc. or monetised by showing ads). New Zealand Failing to investigate the material or to make inquiries of the user concerned may