What is the test for publishing defamatory information?

Publication requires that a plaintiff establish that an individual other than the plaintiff, viewed and understood the defamatory information. As was stated by Deschamps J. in Crookes v. Newton, 2011 SCC 47 [Newton]:

Publication is not complete until someone other than the person referred to receives and understands the defamatory information. Thus, "to shout aloud defamatory words on a desert moor where no one hears them, is not a publication" (Gambrill v. Schooley, 93 Md. 48 (U.S. Md. C.A. 1901), at p. 60). In the context of the Internet, a simple reference, absent evidence that someone actually viewed and understood the defamatory information to which it directs third parties, is not publication of that content.