[oytis]

Still freedom of speech is understood much more literally and with fewer exceptions in U.S. than elsewhere.

In Germany for one, there is no such thing as freedom of speech, but rather "freedom of opinion". Practically that means that if you want to say something that someone else is not going to like, you have to a) take care not to bring up any facts (e.g. say that someone touched you inappropriately), because as soon as you do that you have to either provide a proof or face slander suit b) still not to cross the line when your opinion can be considered offensive. This doesn't leave a lot of space for free speech. This is not to mention a list of forbidden opinions and symbols for which you will face repercussions from the state itself.

Don't want to argue which is the right way, I just mean that "American freedom of speech" is a real thing.

[thefz]

Sorry but that is plain wrong. Freedom of speech in Italy is more or less the same of what you state to be "American freedom of speech", i.e. the right not to be persecuted for your ideas, with some eexceptions being hate speech or incitement to violence. This right includes other forms of communication such as writing and artistic expression.

If you have time to translate this, the Italian form is even a bit less strict in definition : https://it.wikipedia.org/wiki/Libert%C3%A0_di_manifestazione...

[oytis]

> with some eexceptions being hate speech or incitement to violence

These are important exceptions though. Absence of hate speech laws is one thing that makes "American freedom of speech" a pretty unique thing.

[thefz]

That's a step backward, not forward.

[oytis]

I don't think there is such thing as "backward" and "forward" here. They probably contribute to social peace, but put limits to the freedom of speech, which do not exist in the U.S.

[quonn]

> a) take care not to bring up any facts (e.g. say that someone touched you inappropriately), because as soon as you do that you have to either provide a proof or face slander suit

Surely you would face slander suits in the US as well if you lie about being touched?

[oytis]

There is a huge difference in who takes the burden of proof. In the U.S. if you accuse someone of slander, you have to prove that what they say is false and malicious. In Germany it's the other way round: the one who is accused is also the one who should prove that what they say is true.

Which leaves e.g. little space for #metoo in Germany - either you have proofs and then you go to police/court - or you don't, and then you have to stay silent.