Actions alleging harm to a claimant’s reputation by way of defamatory publication on the internet are apt to pose problems in the conflict of laws. When the publication can be accessed almost instantaneously anywhere in the world, which court should have jurisdiction over the action? Indeed, should any one court have jurisdiction in respect of all reputational harm caused worldwide? And what law or laws should apply? The varied solutions adopted in different systems of private international law reveal something about the wider principles underpinning those systems. They also say something about whether those systems consider that a person can only ever have a single reputation to vindicate such that a single natural forum should be identified, or whether it is possible for a person to have a number of different local reputations which properly should be defended in multiple fora.

The decision of the Supreme Court of Canada in Haaretz.com v Goldhar,1 a recent and difficult case on online defamation, is therefore a rewarding comparative study for those with an interest in the conflict of laws.