With the introduction of the Internet real-name system and the Constitutional Court ruling in the early 2010s, multiple research has been executed on the Constitutional Court’s ruling. And as a result, research on freedom of expression and freedom of anonymous expression was intensively conducted until the mid-2010s. Since then, however, almost no research has been conducted on freedom of anonymous expression. Considering the development and changes in online media and Social Networking Services since 2010, the issue needs to be revisited. The content and scope of freedom of expression in ancient Greece and even in the 17th century were very different from today. Even John Milton, the author of Areopagitica, thought that the freedom of the Catholics did not need to be guaranteed. Even after Areopagitica, freedom of expression was emphasized as a very important element during the French Revolution in the process of America’s separation from Britain. The issue of anonymity in freedom of expression has been a continuous issue since the 14th century. Regarding freedom of anonymous expression, the Constitutional Court ruled that the Internet real-name system was unconstitutional in 2012, and about the real-name Internet bulletin board system during the election campaign, it ruled that it was constitutional in 2010 and 2015, but changed its position and ruled it unconstitutional in 2021. However, the Constitutional Court ruled that the identity verification system on public institution bulletin boards was constitutional in 2022, making it clear that freedom of anonymous expression cannot be guaranteed indefinitely. When considering the fact that public bulletin boards are a channel through which the general public can convey their opinions in the realm of ‘nation vs. individual,’ such a decision does not seem to be desirable. Today's media environment is very different from the past. The biggest change is that, unlike in the past, individuals produce more information than any other information-producers. However, in the process, anonymity serves as one of the main causes of fake news and hate speech. Considering all the circumstances, the anonymity in freedom of expression should be guaranteed to the maximum extent possible in the ‘individual-to-state’ dimension, but it would be desirable to guarantee it to a relatively weak level in the ‘individual-to-individual’ domain.
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