South Korea is one of the most advanced IT countries in the world, and thanks to a well-equipped computer network, anyone can easily get access to the Internet. Amid this situation, the posting of the replies was active due to the desire for two-way communication with the news media. However, as the reply culture has not matured compared to the rate of diffusion, the legal dispute over malicious comments has exploded in society. As malicious comments are posted anonymously on Internet news outlets targeting public figures, it is more likely that they will be taken over as contempt rather than defamation. According to the current trends in case law, most of the times, malicious comments are responsible for illegal acts only if they contain swear words, but this is problematic in terms of the regulatory authority. If the malicious comments are included in the expression of humiliation, such as swear words, depending on the type of malicious comments that can be categorized, ask for responsibility for the illegal acts unless there are certain circumstances (Type 1), even if there is no explicit humiliation, it is reasonable to consider a number of factors collectively to estimate the injustability and then require the expressionist to demonstrate the reason for the unlawful sculpture (Type 2).