is there legal precidence of foreign country suing american and, still to them, foreign citizens for public comments on an American service? not a gag, i’m legit curious
Looks like in France there is and if Twitter wants to continue being allowed to exists in France it needs to abide by French law and the laws of any country it is accessible in.
i’m very much not a legal expert, but that seems to me more a France problem. if an American, or a Brit, wants to talk shit on an American platform i feel they shouldn’t be legally liable just because France decides to listen in. if you don’t like how Twitter rolls then cut the platform out of your country
Yeah.
Cutting out those platform from the countries in which they break the law is actually the point; it is those platform problem if they want to make money in a particular juridiction.
Americans have the benefit of the SPEECH Act which makes foreign libel judgments unenforceable in the US if the verdict isn’t compliant with the First Amendment. Musk is probably safe but JK Rowling is in some serious trouble because British libel laws are skewed heavily in favor of plaintiffs.
Its not a libel case actually, its a criminal proceeding that could (or could not) lead to prosecution for cyberbuling, which is a type of penal infraction in France. But from what I know of American law (granted, I know more about other systems), the USA tends to also protect its citizens from other types of judgments as well, and like the majority of western countries, it doesn’t extradite its nationals. I believe the UK is the same way.
You are correct in regards to British Libel laws, but I don’t actually believe this is all that relevant in this case since… its not a libel case, and it wasn’t filed in the UK.
is there legal precidence of foreign country suing american and, still to them, foreign citizens for public comments on an American service? not a gag, i’m legit curious
Looks like in France there is and if Twitter wants to continue being allowed to exists in France it needs to abide by French law and the laws of any country it is accessible in.
i’m very much not a legal expert, but that seems to me more a France problem. if an American, or a Brit, wants to talk shit on an American platform i feel they shouldn’t be legally liable just because France decides to listen in. if you don’t like how Twitter rolls then cut the platform out of your country
Yeah. Cutting out those platform from the countries in which they break the law is actually the point; it is those platform problem if they want to make money in a particular juridiction.
They literally said if Twitter wants to exist in France they need to abide by French law.
Most western countries use the doctrine of being able to prosecute people who have committed crimes against their citizens or people in their country.
Wether or not these facts merit a conviction is something else entirely
Its also not a lible case, btw
By the way musk acts, maybe, hopefully Twitter won’t be available in Europe in general much longer
O got some interesting comments when I asked essentially the same question earlier.
question here
Johnny Depp filed a lawsuit against British newspaper. Carried out in England.
https://en.m.wikipedia.org/wiki/Depp_v_News_Group_Newspapers_Ltd#:~:text=The case was initiated by,the Fantastic Beasts film series.
He lost that case because they proved he beat his wife.
Thus, they were correct when they called him a wife beater.
They didn’t. The verdict literally was “it could have been true, who knows?” which was enough for the newspapaer to win
Americans have the benefit of the SPEECH Act which makes foreign libel judgments unenforceable in the US if the verdict isn’t compliant with the First Amendment. Musk is probably safe but JK Rowling is in some serious trouble because British libel laws are skewed heavily in favor of plaintiffs.
Its not a libel case actually, its a criminal proceeding that could (or could not) lead to prosecution for cyberbuling, which is a type of penal infraction in France. But from what I know of American law (granted, I know more about other systems), the USA tends to also protect its citizens from other types of judgments as well, and like the majority of western countries, it doesn’t extradite its nationals. I believe the UK is the same way.
You are correct in regards to British Libel laws, but I don’t actually believe this is all that relevant in this case since… its not a libel case, and it wasn’t filed in the UK.