of society. In the event the court followed Smith (No. 1) and in doing so the Lord Chief Justice cited from the opinion of Lord Griffiths in Liangsiriprasert v Government of United States of America (1991) 92 Cr App R 77,90. “Unfortunately in this Century crime has ceased to be largely local in origin and effect. Crime is now established on an international scale and the criminal law must face this new reality. Their lordships can find nothing in precedent, comity or good sense that should inhibit the common law from regarding as justiciable in England inchoate crimes committed abroad which are intended to result in the commission of criminal offences in England.” 26. Lord Woolf went on to point out that Liangsiriprasert was applied in Sansom & ors (1991) 92 Cr App R 115 in a judgment delivered by Taylor LJ. Sansom was another conspiracy case and Lord Woolf could see no distinction in relation to the principles of jurisdiction between conspiracy and obtaining by deception. 27. We have to consider whether there is any basis for not applying in the present case the “substantial measure” principle for establishing jurisdiction as enunciated by the Lord Chief Justice in Wallace Duncan Smith (No.4). The starting point seems to us to be the terms of the 1986 Act. Mr Sandiford points out that sections 18, 19 and 23 contain a comprehensive scheme to restrict the public dissemination of written material intended or likely to stir up racial hatred. Section 18 covers display of such written material, section 19 publication and distribution and section 23 possession. In the interpretation section of the Act, section 29 “written material” is described as including any sign or any visible representation. Whilst in 1986 the world-wide web was a thing of the future and computers were in their infancy it seems to us clear that “written material” is plainly wide enough to cover the material disseminated by the website in the present case. The judge took the same view. He said that what was on the computer screen was first of all in writing or written and secondly that the electronically stored data which is transmitted also comes within the definition of written material because it is written material stored in another form. He drew a comparison with opening and closing a book; when the book is open you can see the writing; when it is closed you cannot. 28. The judge was referred to Hansard. Both the appellants and the Crown sought to rely on it. The appellants argue that Hansard makes clear that no consideration was given, when the Bill was debated, to the internet. The Crown argue that the debate illustrates Parliament’s intention was to ensure that “written material” in Part III of the 1986 Act was wide enough to cover new forms of communication so that racist organisations and others could not advance the type of argument being put forward in the present case. 29. For our part we think that the meaning of “written material” as interpreted by section 29 is sufficiently clear to cover the present case without recourse to Hansard. The word “includes” in section 29 is plainly intended to widen the scope of the expression. We reject Mrs Turnbull’s submission that the written material has to be in visible, comprehensible form with some degree of permanence. We also reject the submission that any assistance is to be obtained from the Obscene Publications Act