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A comment on Hotel guest in Thailand jailed for defamation after posting bad online reviews. Parent comment

Re:Hotel guest in Thailand jailed for defamation after posti... by gamblor956 on Sunday September 27, 2020 @06:35PM (#24610737)
It's generally true in most countries, since libel laws extend to keeping private matters private since many things can damage a person's reputation even if they are true. For example, a British Lord's Nazi fetish.

In the US, the publication of private matters is a separate tort, invasion of privacy. For IOP, truth is not a defense.

Or another way of looking at it: libel is a narrower tort in the US than it is in the rest of the world.

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Re:Hotel guest in Thailand jailed for defamation after posti... by rsynnott on Sunday September 27, 2020 @07:27PM (#24611105)
Truth is an absolute defense to libel in the UK. And pretty much everywhere else in Europe, AFAIK.

Some European countries do have quite strict privacy laws, so a newspaper which obtained the material in a questionable way might have to be cautious (see the News International hacking scandal, for instance).

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Re:Hotel guest in Thailand jailed for defamation after posti... by AmericanChopper on Sunday September 27, 2020 @06:57PM (#24610889)
> For example, a British Lord's Nazi fetish

What case was this? Are you sure you're not talking about the Max Mosley (the former racing driver/FIA boss) case against News Group? Because that was a breach of privacy case, not a defamation one.

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Re:Hotel guest in Thailand jailed for defamation after posti... by gamblor956 on Sunday September 27, 2020 @07:31PM (#24611127)
No, the other case happened around the same time or earlier but involved a member of the House of Lords with a fetish for Nazi-themed swingers' orgies.

It was a huge deal for a few weeks, and then it disappeared. I only remember it because my Torts professor brought it up in class during the defamation lecture as an example of the differences between US and UK defamation law.

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