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Joanna lives in Perth, Western Australia. She runs a successful online business selling top quality shoes at a very attractive price point. Her motto is:

Joanna lives in Perth, Western Australia. She runs a successful online business selling top quality shoes at a very attractive price point. Her motto is: "pay less, get more". She is so confident in the quality of her products that she provides a 5-year warranty which enables the customers to return the shoes within a 5-year timeframe without any questions asked. In 2020 Joanna's total sales was worth of $1.2M. 25% of the sales came from Australia, 20% from the US, 15% from Japan, and 7% from France. In addition, a significant number of shoes were sold in the UK, Singapore and South Korea.

Jacob lives in Singapore. He noticed the successful operation of Joanna's business and wanted to follow her success. As a first step, he maps the 4 leading online websites which provide reviews of online businesses. He posts in each website 5 reviews which defame Joanna's business: the reviews say that her shoes are of the "poorest quality on Earth" and that the 5-year warranty is "....nothing but a joke".

Assuming the Australian court has jurisdiction over this dispute, the law of which country will apply? (Please assume that Australian rules of choice-of-law apply).

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