[nullc]

It's also true in the US that you can damage someone gravely through a lawsuit that's ultimately unsuccessful. The UK appears to be worse, both through the total absence of anti-SLAPP protections but also because norms that make it more process-bound willing to entertain such a weak case.

The UK "loser pays" model seems like it would be a benefit, but since the norm that they only pay 70% and that your share can be diminished by presenting a comprehensive case (diminished by every argument you lose) the incentives are complicated and its far from clear to me that it doesn't make it worse.