"The English laws on libel have traditionally favored the plaintiffs. A recent decision by the European Court of Human Rights (in the so-called "McLibel case") held that, on the (exceptional) facts of that case, the burden on the defendants in the English courts was too high. However, it is unlikely that the case will provoke any considerable change in substantive English law, despite strong academic criticism of the current position. [1]
In 1990, McDonald's Restaurants sued Morris & Steel (called the McLibel case) for libel. The original case lasted seven years, making it the longest-running court action in English history. Beginning in 1986, London Greenpeace, a small environmental campaigning group, distributed a pamphlet entitled What’s wrong with McDonald’s: Everything they don’t want you to know. The pamphlet claimed that the McDonald's corporation sells unhealthy food, exploits its work force, practices unethical marketing of its products towards children, is cruel to animals, needlessly uses up resources and creates pollution with its packaging and is responsible for destroying the South American rain forests. Although McDonald's won two hearings, the widespread public opinion against them turned the case into a matter of embarrassment for the company. McDonald's announced that it has no plans to collect the £40,000 it was awarded by the courts, and offered to pay the defendants to drop the case. Since then, certain aspects of the trial have been declared by the European Court of Human Rights to be in violation of the Convention on Human Rights."
"Defamation law in the United States is much less plaintiff-friendly than its counterparts in European and the Commonwealth countries.
This is because the First Amendment to the Constitution of the United States gives strong protection to freedom of expression, which arose from the tradition of dissent in the American Revolution. For most of the history of the United States, constitutional protections of freedom of speech were not considered applicable to libel law. This changed with the landmark 1960s case of New York Times v. Sullivan, in which the Supreme Court of the United States modified the law of libel to be in accord with constitutional requirements. The court held that where a public figure was defamed, the plaintiff had to prove not just that an untruthful statement was made, but also that it was made with actual malice - that is, that it was made knowing it to be false or with reckless disregard for the truth. This decision and the ones that followed its lead created a major revolution in the doctrine of libel law.
One very important distinction today is that European and Commonwealth jurisdictions adhere to a theory that every publication of a defamation gives rise to a separate claim, so that a defamation on the Internet could be sued on in any country in which it was read, while American law only allows one claim for the primary publication."
http://en.wikipedia.org/wiki/Libel#Modern_law
Just thought it was an interesting difference, and something the LC boys might want to take into account.