recognise any order made in those circumstances by an Australian court. That is true.  And Gutnick v Dow Jones is a good example of this.  But is this the issue?  How often does this occur?  Most cases, as occurs in most litigation, involves parties that have a presence in the jurisdiction.  Extra territorial enforcement can be complicated in commercial disputes.  But that is not a reason for having a cause of action. Michael Rivette : How you really stop it is for the individual who's about to post the photo to actually know that that's the wrong thing to do. That's where you stop it. If you have something that's clearly defined, that's spoken about, that's in the press, that...it becomes part of the social conscience, and people realise, if they go, 'Whoops, should I post this or not, because there's that cause of action called privacy? I won't post it', then the law is actually working, but the moment people don't understand and appreciate the boundaries... While that may be the case on some level the purpose of a cause of action is to allow a person to bring an action and, in this case, protect a right.  The educative value is very much a secondary issue, if that.  As Sam Goldwyn said "if you want to send a message, use Western Union." Legislators should always be wary of legislating sending messages. Damien Carrick : I'm sure it's happening in France and Germany and other places where the law