to go to trial is believed to be Mickle v Farley. The defendant, former Orange High School student Andrew Farley was ordered to pay $105,000 to a teacher for writing defamatory remarks about her on the social media platform. A more recent case in defamation law was Hockey v Fairfax Media Publications Pty Limited [2015], heard in the Federal Court of Australia. This judgment was significant as it demonstrated that tweets, consisting of even as little as three words, can be defamatory, as was held in this case. Regarding defamation on the internet, in 2011 the Supreme Court of Canada held that a person who posts hyperlinks on a website which lead to another site with defamatory content is not publishing that defamatory material for the purposes of libel and defamation law. In Singapore, Division 2 of Part 3 of the Protection from Harassment Act 2014 provides for individuals who have been affected by false statements online to seek a variety of court orders under the tort of harassment that are not available under the pre-internet tort of defamation: Stop Publication Order (an order requiring the tortfeasor to stop making the defamatory statement) Correction Order (an order for the tortfeasor to publish a correction of the statement) Disabling Order (an order requiring an internet-based intermediaries to disable access to the defamatory statement). This is distinct from and does not affect plaintiffs right of action under the common law torts of libel and slander as modified by the Defamation Act 1957. The Protection of Harassment Act 2014, which provides for criminal penalties in addition to civil remedies, is specifically designed to address a narrower scope of conduct in order to avoid outlawing an overly broad range of speech, and is confined to addressing speech that causes "harassment, alarm, or distress". Beyond simply addressing novel instances of defamation enabled by the rise of the internet, courts around the world have also had to deal with complex jurisdictional issues regarding trans-border online defamation. On 10 December 2002, the High Court of Australia responded to this emerging phenomenon by vastly expanding the international jurisdiction of Australian courts in its judgment in Dow Jones v Gutnick. The judgment established that internet-published foreign publications that defamed an Australian in their Australian reputation could be held accountable under Australian defamation law. The case gained worldwide attention and is often said, inaccurately, to be the first of its