>but if someone is going to equate two things that are treated differently under both American and other (UK, for example) laws, it's a relevant point.

It's relevant insofar as legal distinctions between US and UK are relevant, which is to say, not relevant at all so far as I can tell. I don't think anyone's argument here hinged on such a distinction. If it did, and to that extent, it's relevant. But the heartland of this whole conversation has to do with a conception of speech as a principle that's broader than just U.S. law.

So we should be clear about the extent to which this is, or isn't, speaking to the conversation that everyone else is having.