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

Contents:

Introduction
Paul Wragg and András Koltay

Theoretical considerations
1. The origins and development of the right to privacy
John Campbell

2. Privacy and incrementalism
Thomas D.C. Bennett

3. Theories of reputation
Jan Oster

4. Separated by a common language: The anti-paternalism principle in US and English defamation and privacy law
Paul Wragg

Privacy laws compared
5. Weighing content: Can expression be more or less important?
Categorical or case by case balancing and its (respective) disposition to rank relevance of communication
Matthias 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 Reichel

7. Do we need to separate privacy and reputation? USA, Europe and Korea compared
Kyung Sin Park

8. Public Image (Un)Limited: Privacy rights of the photographic subject in England and New York compared
Rebecca Moosavian

9. What newsworthiness means
Amy Gajda

10. Defamation by photo-manipulation under New Zealand law
S. Che Ekaratne 

Data protection
11. A European and German perspective on data protection law in a digitised world
Sebastian Bretthauer

12. Right to be forgotten in the global information economy
Joanna Kulesza

13. Enforcing privacy through individual data access rights – a comparative study
Rolf H. Weber and Dominic N. Staiger

Defamation laws compared
14. Defamation: A half-century of changes (more or less)
Russell L. Weaver

15. A comparative analysis of the treatment of corporate reputation in Australia and the UK
Peter Coe

Defamation, PRIVACY and New technologies
16. Liability of Internet intermediaries for defamation: Beyond publication and innocent dissemination
David Rolph 

17. Defamation on the Internet: The role and responsibilities of gatekeepers
András Koltay

18. Privacy, remedies and comity: The emerging problem of global injunctions and some preliminary thoughts on how best to address it
Ron Krotoszynski

Country chapters
19. Free speech and the rights relating to the personality involving politicians in French law
Guilhem Gil

20. Italian defamation and privacy law from a comparative perspective
Vincenzo Zeno-Zencovich

21. Canadian defamation and privacy law in comparative context
David 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 protections
Mark Pearson and Virginia Leighton-Jackson

23. South Africa’s reasonable publication defence and the United Kingdom’s public interest defence: Two sides of the same coin?
Dario Milo

24. Defamation and privacy law in Japan – from a comparative perspective
Jun Shimizu

25. The Chinese defamation law four decades on (1979–2019): Legal rules versus political uncertainties
Mei Ning Yan

Index