On 5/5/05, Tony Sidaway minorityreport@bluebottle.com wrote:
Josh Gordon said:
Don't British and US law differ in this regard?
Not much consolation if you're an American sued in a British court for something you put on an American website. Yes, they do have jurisdiction. Yes, litigants have successfully collected.
The difficult thing in the UK is that the burden of proof lies with the defendant i.e. the publisher, who has to show why the material is not libellous; whereas in the U.S., the burden of proof lies with the person who brings the case.
Sarah