Is a reference, devoid of context, a publication of defamatory information to a third party?

A reference, devoid of context, has never amounted in law to publication of the information to which it directs the third party. To so hold would be to disregard the bilateral nature of publication. 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 (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.