Abstract
Abstract Around the world, criminal and civil laws, collectively known as the law of defamation, are designed to deter false attacks on an individual's reputation. However, the amount of speech punishable with these laws varies greatly from nation to nation. On one end of the spectrum, the United States protects even false statements of fact about public plaintiffs unless actual malice is shown. On the other, in China insulting statements need not contain false information to be actionable. As the internet unites the world through instantaneous communication, the differences in these legal protections have begun to present global communicators with numerous challenges.
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