In Williams v. Daily Review, Inc. (1965) 236 Cal.App.2d 405, plaintiffs, engineering contractors on a job with the City of Hayward, complained of a newspaper article which insinuated they were responsible for delay in completion of a street repair project and were incompetent, both in the preparation of their bids and in the performance of the job. In upholding the trial court's instruction to the jury that the communication was privileged under section 47, subdivision 3, this court reasoned as follows: "In California the 'fair comment' privilege is encompassed within the provisions of subdivision 3 of section 47 . . . . It has been held that this qualified privilege exists whether the publication be in the form of opinion or of false statements of fact . . . .. The crucial issue involved in determining the applicability of the 'fair comment' privilege is whether or not the publication was made in the public interest . . . . Contrary to plaintiffs' contention, the scope of the term 'public interest' in California is not limited to matters relating solely to public officials. Both the cases of Glenn and Maidman applied the privilege to statements defaming private individuals, where the subject matter of the article was determined to be of public interest or the defamed individual of renown among a certain interest group." ( Id., at pp. 416-417.)