It does not help that it is just a small number of cases, as even a small number of cases will have have a chilling effect on free speech. The "somewhere betwe

It does not help that it is just a small number of cases, as even a small number of cases will have have a chilling effect on free speech. The "somewhere between UK and US" comment is theoretical and is about what the written law says. The way it is practised is clearly worse than both. You don't have to watch your back when you criticize a politician in the UK, and certainly not when you "like" someone doing that. Even if it was later criticized later on, it did happen, and I would guess it got no consequences for the people that prosecuted the two women.