In Brown v. Kelly Broadcasting Co. (1989) 48 Cal.3d 711, the Supreme Court explained the history and meaning of the statute: "It was enacted as part of the Civil Code in 1872. At that time, in the common law of England and the United States, defamation was subject to strict liability, that is, liability without fault as to truth or falsity. . . .To ameliorate the harshness of the strict-liability standard, certain privileges and defenses developed in the common law. . . . The common-interest privilege . . . protected communications made in good faith on a subject in which the speaker and hearer shared an interest or duty. This privilege applied to a narrow range of private interests. The interest protected was private or pecuniary; the relationship between the parties was close, e.g., a family, business, or organizational interest; and the request for information must have been in the course of the relationship."