Abstract
As the editors of this edited collection on comparative privacy and defamation András Koltay and Paul Wragg point out, most of the literature on the topic focuses on the United Kingdom and the United States, so their book is a welcome attempt to expand the theoretical, doctrinal and practical discussion on these two very important areas of law. The book is truly global in scope, including contributions from around the world with the aim of enriching the scholarship in the field. It starts with an Introduction, which briefly mentions the main strength of the book – namely, its wider geographic focus, but does not really elaborate on the common questions/issues guiding the volume. The book is then split into five parts. Part I, ‘Theoretical Considerations’, consists of four theoretical chapters on the history of the right to privacy, privacy and incrementalism, theories of reputation and the antipaternalism principle in the United States, and English defamation and privacy law. Part II, ‘Privacy Laws Compared’, includes contributions from a range of contexts, such as Europe, the United States and South Korea, and different aspects of privacy, such as reputation, public officials and official documents, photographs and newsworthiness. Part III, ‘Data Protection’, comprises three chapters on Germany, the right to be forgotten and individual data access rights from a comparative perspective. Part IV, ‘Defamation Laws Compared’, consists of two chapters discussing historical changes in defamation law and corporate reputation in Australia and the United Kingdom. Part V, ‘Defamation, Privacy and New Technologies’, deals with issues such as defamation on the Internet and liability of Internet intermediaries, and privacy, remedies and comity. The final part, ‘Country Chapters’, has seven chapters on different countries: France, Italy, Canada, Australia, South Africa, Japan, and China. While the book offers an invaluable attempt to expand defamation and privacy scholarship beyond the UK–US contexts, it would have benefitted from a stronger Introduction and a Conclusion at the end bringing the volume together.