>The Court reasoned that only once Google acquired knowledge of the paragraphs by reason of Dr Duffy’s notifications and failed to remove them within a reasonable time thereafter would the necessary mental element be present for Google to be a “secondary publisher”.
> ...
>The Court then turned to look at the notice given by Dr. Duffy, to ascertain whether it was sufficient to fix Google with the relevant mental element. The Court concluded that Dr Duffy’s communications with Google comprised adequate notification to them of the allegedly defamatory material, this was despite the fact that some of the URLs were incomplete in these communications. The Court also implied that a reasonable time for removal of content would be one month, which had not been met by Google.
>...
>The Court rejected Google’s defenses of innocent dissemination, qualified privilege, and justification (truth). In dismissing the innocent dissemination defense, which required that the publisher be a subordinate distributor who did not know or ought not to have known that the matter was defamatory, the Court stated that the defamatory nature of the content was self-evident from an examination of it.
Emphasis on the last line.
It's not like she had to go to Google and say, "here is a court judgment showing this content is defaming me" to have it removed. She simply had to notify Google that this "self-evident" defamatory content was being served by them.
That seems like a significant precedent to set. I don't really think it is fair to expect Google to determine which content is "self-evidently" defamatory (edit to add: amongst all the takedown requests they will receive)