U.S. President Obama today signed into law the “Speech Act,” which is aimed at protecting U.S. writers from foreign libel judgments from jurisdictions that, in the opinion of a U.S. court, do not adequately protect freedom of speech. Such foreign judgments will not be enforceable in the United States — where, presumably, the writer’s and publisher’s assets are located. The legislation was prompted, as the BBC report says, by a libel suit against American writer Rachel Ehrenfeld who was sued in England, a notorious destination for libel tourism, because of a book on the funding of terrorism.
I believe that the text of the law can be found here; if this is not the final version of the legislation, I’d be happy to learn that from your comments.
Canadian libel judgments would, of course, be considered foreign judgments. Would our libel law differ so much from U.S. law that enforcement of our judgments would be seen as failing to “protect the right to free speech under the First Amendment to the United States Constitution”?