Out-law.com reports a recent decision of the Court of Appeal for England and Wales, R. v. Sheppard and Whittle, upholding a conviction for publishing hate literature though the material was stored on servers in California.
The connecting factor was that a “substantial measure of the activities” of the accused took place in England.
This is consistent with the Canadian decision in Citron v Zundel (Canada Human Rights Commission), where the material was also on a California server.
The English (and Welsh) Court held that the material could be held to be published without evidence that anyone actually read it. . . . [more]