Comparative Privacy and Defamation

Edited by András Koltay, Professor of Law, National University of Public Service and Pázmány Péter Catholic University, Hungary and Paul Wragg, Associate Professor of Law, University of Leeds and Associate Fellow, Honourable Society of the Inner Temple, UK

'Comparative Privacy and Defamation couldn't be more timely and relevant to freedom of expression academics and practitioners in the global 21st century. More wide-ranging and in-depth than other similar publications, the book is a remarkable contribution to international, foreign, and comparative law. Its topical comprehensiveness and authorial diversity and prestige will make the volume a must read for those interested in the subject.'--Kyu Ho Youm, University of Oregon, US'Wragg and Koltay's thought-provoking book makes an important contribution to the literature. They have brought together an impressive group of experts from the world scene. Whereas most books speak narrowly to the Western picture of defamation and privacy law, theirs is a refreshing take by bringing in wider, global perspectives. In doing so, they are strikingly effective in raising new ideas and asking new questions at a time when the political climate is calling out for both.'--Alastair Mullis, University of Leeds, UK

• Contents:Introduction Paul Wragg and András KoltayTheoretical considerations1. The origins and development of the right to privacyJohn Campbell2. Privacy and incrementalismThomas D.C. Bennett3. Theories of reputationJan Oster4. Separated by a common language: The anti-paternalism principle in US and English defamation and privacy lawPaul WraggPrivacy laws compared5. Weighing content: Can expression be more or less important?Categorical or case by case balancing and its (respective) disposition to rank relevance of communicationMatthias Cornils 6. What is it the public has a right to know? The right to privacy for public officials and the right access to official documents – European and Swedish perspectives Jane Reichel7. Do we need to separate privacy and reputation? USA, Europe and Korea comparedKyung Sin Park8. Public Image (Un)Limited: Privacy rights of the photographic subject in England and New York comparedRebecca Moosavian9. What newsworthiness meansAmy Gajda10. Defamation by photo-manipulation under New Zealand law S. Che Ekaratne Data protection11. A European and German perspective on data protection law in a digitised worldSebastian Bretthauer12. Right to be forgotten in the global information economy Joanna Kulesza13. Enforcing privacy through individual data access rights – a comparative studyRolf H. Weber and Dominic N. StaigerDefamation laws compared14. Defamation: A half-century of changes (more or less)Russell L. Weaver15. A comparative analysis of the treatment of corporate reputation in Australia and the UK Peter CoeDefamation, PRIVACY and New technologies16. Liability of Internet intermediaries for defamation: Beyond publication and innocent disseminationDavid Rolph 17. Defamation on the Internet: The role and responsibilities of gatekeepersAndrás Koltay18. Privacy, remedies and comity: The emerging problem of global injunctions and some preliminary thoughts on how best to address itRon KrotoszynskiCountry chapters19. Free speech and the rights relating to the personality involving politicians in French lawGuilhem Gil20. Italian defamation and privacy law from a comparative perspectiveVincenzo Zeno-Zencovich21. Canadian defamation and privacy law in comparative contextDavid Mangan 22. Privacy and defamation in Australia: A post-colonial tango, or the operation of privacy and defamation in Australia without formal constitutional free expression protectionsMark Pearson and Virginia Leighton-Jackson23. South Africa’s reasonable publication defence and the United Kingdom’s public interest defence: Two sides of the same coin?Dario Milo24. Defamation and privacy law in Japan – from a comparative perspectiveJun Shimizu25. The Chinese defamation law four decades on (1979–2019): Legal rules versus political uncertainties Mei Ning Yan Index