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Re:'Right to be forgotten' could threaten global free speech... by Tomte on Monday September 10, 2018 @12:57PM (#17953175)
Exactly. America does "1A trumps everything", while Germany does "practical concordance" where it recognizes that basic rights are in a complicated relationship affecting each other, and where courts should interpret basic rights in such a way that a global maximum is reached where all those rights retain as much of their meaning and content as possible.

I think the French do the same (and have even taken the term "practical concordance"), but I'm not really sure.

Re:'Right to be forgotten' could threaten global free speech... by M2Ys4U on Tuesday September 11, 2018 @05:26AM (#17958246)
I would be _very_ surprised if there was much difference between approaches, given that they're both members of the Council of Europe (and thus the European Court of Human Rights)