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doctrine of comity among nations for a practical and achievable solution that recognises both national rights and the reality of universal dissemination of publications. Comity is a useful doctrine for international issues because it is built on approximations and accommodation. For a legal doctrine, comity has a great deal of flexibility and we should take advantage of that give-and-take to harmonise judgments across jurisdictions. In connection with the application of comity, the differences among national defamation laws are evaluated and sometimes even reconciled. Although libel tourism is not limited to only situations in which American authors are being sued in London but rather is alleged whenever an American interest is sued in a non-American forum, the approach of this text will deal primarily with Anglo-American conflicts. This reflects both the significance of these two countries as sources of English-language publications and the fact that most of the reported conflict arise in the Anglo-American context.
Although the primary focus of this study is on the English and American legal systems, the total geographic scope of this book includes several of the major English common-law countries. Defamation laws invariably restrict free speech and all of the English-speaking countries have defamation laws. However, the common law has traditionally permitted little slack in tolerating inaccurate publications while the First Amendment seems to provide publishers and writers with considerable room to disseminate falsehoods without fear of legal retribution, except in cases of intentional defamations. However, all is not quite what it seems and once the greasepaint of popular belief is peeled away, the national laws are actually far more alike than dissimilar.
While the phenomenon of libel tourism might be new to American First Amendment lawyers and their clients, it is really not all that different from the no-fault or cookie-cutter Mexican divorces that once challenged domestic-relations practitioners and courts in the United States. These Mexican divorces provided a proving ground for comity, and the US law of comity is now well-equipped, seasoned, and honed to deal with a wide variety of international situations. The predilection of comity is to enforce non-US judgments as a matter of sound public