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It's not what I think.

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Freedom of Speech

Whatever you think of free speech in the US, we have an absolute right to free speech. This means that the government is prohibited from infringing on it. If the government wrote such a law, it would be struck down by courts. And bad arrests often result in the person being let go. The limits are pre-defined and set.

Europe and the UK, in contrast, have a qualified right to free speech. The governments get to decide what is reasonable free speech, which changes with their chosen interpretation, or can be simply rewritten. It seems like lately the UK has been the epicenter of testing the limits of free speech.