President Obama has signed into law the SPEECH Act – a bill which effectively protects US citizens from the effects of libel tourism.
The SPEECH Act will enable US courts to refuse to enforce any libel case judgments made abroad unless they decide that the free speech protections given in a particular foreign court matchs those given in the US.
The move means that judgments in the High Court will be unenforceable in the US.
One of the major differences between US and English libel law is burden of proof. In the US claimants have to show that material published about them is false – while under English law the burden of proof is on the publisher.
It is also more difficult for public figures to sue in US courts. They have to show malicious intent or recklessness.
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