the less derogatory meaning would also be unreasonable: it would be naïve.” 47. 48. As regards principle (3), the following statements help ‘unpack’ the content of this briefly-stated but key principle: (1) Judges should have regard to the impression the words have made on themselves in considering what impact it would have made on the hypothetical reasonable reader (per Eady J in Gillick v Brook Advisory Centres cited by the CA at [2001] EWCA Civ 1263 at [7]). The exercise is one of impression (per Warby J in Simpson v. MGN Limited [2015]EWHC 77 (QB)). (2) The meaning of words is often a matter of subtlety, going well-beyond what they literally say (per Warby J in Rufus v. Elliot [2015]EWHC 807 (QB) at [21]). (3) The defamatory sting of words often lies not so much in what the words themselves say, but also “what the ordinary man will infer from them” (per Lord Reid in Lewis v. Daily Telegraph [1964] AC 234, 358. (4) In putting itself in the shoes of the notional ordinary reader, the court must allow for “a certain amount of loose-thinking” (per Lord Reid in Morgan v. Odhams Press Ltd [1971] 1 WLR 1239, 1245). Or, as Lord Devlin put it in Lewis (ibid at p.257), the court must allow for the fact that a laymen reads in an implication much more freely than a lawyer. (5) It is also important to bear in mind that such a person would normally read (or hear) the relevant words once and would therefore get a broad impression of what is said; and that the layman would not engage in the sort of minute analysis (textual or legal) that a lawyer would (per Sharp LJ in Rufus v. Elliott at [19]). This is a fortiori where the words complained of are part of a radio or television broadcast where the ability to re-read the words is unlikely to be available or readily used (see further below). (6) The court should avoid a minute linguistic analysis of every phrase or engaging in a protracted exercise in logical positivism (per Lord Diplock in Slim v Daily Telegraph Ltd [1968] 2 QB 157 at 171-2). (7) It is difficult to draw the line between pure construction and implication, and the layman's capacity for implication is much greater than the lawyer's (per Lord Diplock in Lewis v Daily Telegraph Ltd [1964] AC 234 at 277). Principle (6) requires the court to form a view on how the representative hypothetical reader of the particular publication concerned would be likely to understand the words, bearing in mind where in the publication the words appear; the reader’s familiarity with the nature of the publication in question; and any expectations created by that familiarity (per Warby J in Simpson v. MGN Limited [2015]EWHC 77 (QB) citing Eady J: see John v Guardian Newspapers Ltd [2008]EWHC 3066 (QB), [22] [23], [32]). The exercise needs to be undertaken with care. The court can take judicial notice of facts which are common knowledge, but facts which are not need, in principle, to be admitted or proved, not assumed. The court should be wary of reliance on impressionistic assessments of the characteristics of a newspaper’s readership (per Warby J in Simpson v. MGN Limited [2015]EWHC 77 (QB)). 11