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Its not as clear cut as it appears.

Its expensive and painful to bring and defend a libel claim.



In the US, the plaintiff must prove the statement was false.

In the UK, the defendant must prove the statement was true.

In practice, this makes the UK setup pretty nasty (long, expensive, high risk), even when it arrives at the correct result. https://en.wikipedia.org/wiki/Irving_v_Penguin_Books_Ltd




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