In the US, the plaintiff must prove the statement was false. In the UK, the defendant must prove the statement was true. In practice, this makes the UK setup

In the US, the plaintiff must prove the statement was false. In the UK, the defendant must prove the statement was true. In practice, this makes the UK setup pretty nasty (long, expensive, high risk), even when it arrives at the correct result. https://en.wikipedia.org/wiki/Irving_v_Penguin_Books_Ltd https://en.wikipedia.org/wiki/Irving_v_Penguin_Books_Ltd