CAFC discusses "printed publication" in Suffolk v. AOL: the matter of "sufficient dissemination"
the ultimate reason Suffolk’s argument fails,
a printed publication need not be easily searchable
after publication if it was sufficiently disseminated at the
time of its publication. See, e.g. ,
In re Klopfenstein, 380F.3d at 1350–51.
Thus, the question becomes whether the
Post was sufficiently disseminated.