Republication

The doctrine of republication operates as an exception to the single-publication rule in defamation actions. Republishing material in a new edition, editing and republishing it, or placing it in a new form resets the statute of limitations. This exception protects a plaintiff by providing "a remedy where the defendant edits and retransmits the defamatory material, or distributes the defamatory material for a second time with the goal of reaching a new audience." Determining instances of republication is fact intensive. Generally, a website is republished when its content is "substantially modified." Atkinson v. McLaughlin, 462 F.Supp.2d 1038, 1052 (D.N.D. 2006) (citing Churchill v. State, 876 A.2d 311, 317 (N.J. Super. 2005); Firth, 775 N.E.2d at 465); see also American Dental Ass'n v. Khorrami, 2003 WL 24141018, at *5 (C.D. Cal. 2003) (noting that the single-publication rule applies to the Internet so long as the statement "is not substantially changed after its initial appearance.").