The UK and USA both have common law systems, where judges have the freedom to establish precedence in regards to matters of law. I believe most of continental E

The UK and USA both have common law systems, where judges have the freedom to establish precedence in regards to matters of law. I believe most of continental Europe operates on civil law systems where judges have much less room for interpretation. On the matter of defamation the US is quite different from everywhere else though, because of the 1st amendment, and the 'actual malice' standards applied to 'public figures' in defamation cases. The confounding factors in the EU are the privacy clauses in the European Convention on Human Rights, so you see cases that would be related to defamation elsewhere being litigated on privacy in the EU.