Not entirely, there are differences. For example in the UK there is no equivalent to section 230 and companies and individuals have been sued for making rude comments. One man got fined for teaching his dog to raise its right front paw whenever he asked it to gas the Jews - because it was obscene and rude.
No, they will not. You seem to think, on a European forum no less, that the entire world not only respects, but also considers US law, more or as important as their own. We do not. My opinion, and this is widely shared here, is that the USA is not the shining beacon of light and freedom that it was in the past. We don’t really care - your lawmakers are a joke and they have failed not just you, but the west in general.
When we think of freedom of speech in Denmark there are two things that come to mind:
- Our constitution, which says:
§ 77. Enhver er berettiget til på tryk, i skrift og tale at offentliggøre sine tanker, dog under ansvar for domstolene. Censur og andre forebyggende forholdsregler kan ingensinde påny indføres.
- The “racism law”
§ 266 b. Den, der offentligt eller med forsæt til udbredelse i en videre kreds fremsætter udtalelse eller anden meddelelse, ved hvilken en gruppe af personer trues, forhånes eller nedværdiges på grund af sin race, hudfarve, nationale eller etniske oprindelse, tro eller seksuelle orientering, straffes med bøde eller fængsel indtil 2 år.
Stk. 2. Ved straffens udmåling skal det betragtes som en særligt skærpende omstændighed, at forholdet har karakter af propagandavirksomhed.
And in the UK it’s different as someone just posted above. And in Germany it’s different again.
I will translate - loosely because it’s fairly old Danish and a little hard to translate, but hopefully I get the point across as accurately as I can:
§ 77: Anybody are permitted to in print, in writing, or in speech, to publish and share his/her thoughts, but only under penalty of the courts. Censorship and other pre-publication measures can never again become law.
§ 266 b. Any who publicly, or with deliberate intent on spreading the information to a wider audience or other platform, publish information in which a group of people is threatened, demeaned, or degraded because of race, skin colour, national or ethnic background, faith, or sexual orientation, shall be punished with fines or prison up to 2 years.
Part 2: When doling out the punishment it should be considered extra serious if the offence can be considered propaganda.
So here homophobia is specifically not legal, and this has caused an uproar of debate for many, many years. I shall not go into the specifics, but suffice to say there’s several groups of people here, though LGBT groups are not among them, which people really do not like.
Being a publisher or a social network makes no difference here. Being an internet provider, however, does make a difference. Here the protection is about transmitting information, not storing or hosting it. There are no protections for that.
There are also some laws going in the other direction - for example in Denmark it is actually illegal to prevent a legal licensee of a piece of art, digital or not, from making backup copies for personal use.
What that effectively means is that most DRM schemes known today are illegal. Blizzard’s is not because they provide a backup for you and you can copy the data however many times you like, but what most BluRays do is illegal - but nobody really seems to dare fight against it due to the implications of Denmark not getting movies anymore.
Anyway, suffice to say, it’s complicated. Just deferring to US law is meaningless to us.