Eady J went on to distinguish "Godfrey" as a case of continued publication of the same defamatory statements after receipt of the plaintiff's request of removal. "Bunt" was different because the claimant was relying on separate postings. His Lordship further remarked that the position of an ISP is not analogous to that of a distributor. While a distributor may need to prove an absence of negligence to establish a defence of innocent dissemination, his Lordship said persons who truly fulfil no more than the role of a passive medium for communication, such as ISPs, cannot be characterized as publishers and hence "do not need a defence".