[jackgavigan]

You've hit the nail on the head. A company is only subject to UK law if it operates from the UK. Facebook's European office is in Dublin, which is why it is subject to Irish/EU privacy legislation.When Twitter establishes its European office, it will similarly become subject to the same laws.

As far as I know, Klout has no UK/EU presence so it's not subject to these laws.

[vidarh]

> A company is only subject to UK law if it operates from the UK.

That's wrong.

This is the UK's Crown Prosecution Service advice on the matter:

http://www.cps.gov.uk/legal/h_to_k/jurisdiction/

As you can see, it sets out a long range of situations where UK jurisdiction extends outside the UK, in many cases even if the criminal behavior happened entirely outside of the UK.

I'm not a lawyer, and I don't know all the details and whether or not it'd be likely to be possible to get a court in the UK to accept jurisdiction in a case against Klout, but courts in the UK have a lot of flexibility and the fact that they are in the US by no means automatically means UK courts won't or can't claim jurisdiction.

[alexchamberlain]

Passive personality is particularly interesting.

[alexchamberlain]

I wonder if this is entirely true... By accepting registration from EU users, are they operating in the EU and thereby subject to EU law?

[salvadors]

I don't believe so. If I walk into a store in New York and tell them I'm from the UK, they won't suddenly become subject to UK/EU law if they choose to serve me. I'm the one subjecting myself to US law if I shop there, not vice versa.

Further, even if they were subject to EU law on this, how would any action for a breach be enforced?

[alexchamberlain]

But you are on US soil when you walk into that shop. There are many examples of UK firms not selling to US clients - poker firms, National Lottery...

[cstross]

That's my understanding.