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Existing California law provides that the statute of limitations for defamation based on a statement in a published book runs from the date the book was first generally distributed to the public, regardless of the date on which the plaintiff actually discovered the defamatory book or contents.  A recent decision of the California Supreme Court now clarifies that this single-publication rule for defamation claims, regardless of a plaintiff’s delayed discovery, applies even when the defamatory material is in a publication of very limited or obscure distribution.  In the case at issue, the allegedly defamatory statements were contained in interview transcripts compiled as part of an oral history project and archived at a library of the University of California at Berkeley, and fewer than ten copies of the offending transcripts were published.  According to the California Supreme Court, its ruling applies to “all publications”, even very limited-circulation ones, unless access is forcibly restricted, and thus arguably may apply to publications on the Internet other than restricted-access sites.  (Hebrew Academy of San Francisco v. Goldman, California Supreme Court No. 414796, December 27, 2007).

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