[rafaelmn]

I went to the site and sorted by fine - I needed to go to the bottom of second list to find a non US company ? By the time I get to pages that are mostly non US companies the fines are two orders of magnitude smaller and dropping fast - do you have any aggregate view to compare ? I would not be surprised at all that indeed most of the fines were towards US companies in total amount.

[oblio]

I saw TikTok at #3 and #5, Enel (Italian) at #15, Vodafone at #19 (British) and starting at around #21 the list is basically dominated by European companies.

Speaking from personal experience, American companies, especially the big ones, tend to treat everyone else as "Americans that they don't know they're American yet" or alternatively "slightly dumb Americans".

At least for one of them, yeah, they apply the legal laws, but the general decisions are taken in the US with little regard for local "non-impeding laws", I would call them. "Impeding laws" would be laws that would block the launch of something (for example they wouldn't attach an AR-15 to every product sold). "Non-impeding laws" would for example be, labor laws. They just assume that what works in the US sort of works everywhere else and deal with the consequences along the way.

[rafaelmn]

I count TikTok as big tech non-EU so I automatically put it in to that bucket but you are right it is not a US company. Still fits the theme that EU is using GDPR to shake down big tech it does not own. I missed Enel (did not know about them) and yeah Vodafone was bottom page 2 first EU brand I recognized from the list, but OK middle of page 2 for non-EU.

Again just a rough feeling from the list but I would speculate that over 50 percent of fines in total were towards US or non-EU based companies.

[vampirical]

Please re-read what you’ve written in these two comments with a critical eye. You’re speaking from a lack of knowledge without very much care and reaching incorrect conclusions that agree with your initial bias. When someone else does the work of helping nudge you towards reality you seem to be doing a poor job correcting. Sorry if this comes across as rude, it’s said with the kindest of intentions.

[rafaelmn]

So I did quick excel math - I took just the US companies from top 100, sumed them and then I summed everything else (the entire list, not just top 100) - including tiktok - and the ratio is almost 3 to one against US companies in total.

In fact Meta alone is fined more than everyone else combined.

What exactly am I missing ?

[oblio]

The fact that the EU just doesn't have big companies in the fields that are more likely to be abusive with customer data.

It's a bit like the sweatshop argument. If your company wins out by using sweatshops, yeah, you're going to end up with the billion dollar argument. But if a certain market doesn't want stuff produced by sweatshops, and they decide to dis-incentivize it by tariffing it, that:

a) makes sense from their point of view

b) is moral from a global perspective

Similar approach here.

[rafaelmn]

Thats all a matter of perspective, not something I am willing to argue. EU has a history of making protectionist legislation under the guise of protecting its members, eg. the whole GMO story, and I can see how someone can make an argument here. If it is valid or not is up to you I guess.

But saying that the fines are mostly towards EU members when over 2/3 is fined towards US companies is misrepresenting the data and the opposing viewpoint.

[oblio]

Fixing a typo:

* you're going end up with the billion dollar company

[noirscape]

> big tech it does not own

If a company does business in the EU, it's dealing with EU citizens, giving the EU jurisdiction over how that business is conducted.

The EU absolutely has full legal standing for this; if big tech doesn't want to abide by it, they can always leave the EU.

American companies get fined more often for the simple reason that they break the GDPR more often since the US lacks the same legal privacy framework, which means they don't have the same incentive to comply with it and instead try to rules lawyer around it.

[piva00]

> Still fits the theme that EU is using GDPR to shake down big tech it does not own.

It's not a shake down, it's the fucking law which they don't follow and have to pay fines accordingly. Every single business in the EU has to follow these laws, if the US-based ones are not taking proper measures to not act illegally that's on them, not on the legislation, this shake down narrative is quite tired by now.

> Again just a rough feeling from the list but I would speculate that over 50 percent of fines in total were towards US or non-EU based companies.

Perhaps because the US companies are more eager in breaking laws and figuring it out later? Isn't that the whole take on EU vs US business approach, the US ones are big risk takers (including in acting illegally) vs EU ones being risk-averse?

I feel disheartened that this narrative is still spewed on HN, it's just vitriol, the US companies are breaking the law of EU members, if they do business here they need to follow the law, it's absurdly simple.

[rafaelmn]

This isn't something I really care to argue - OP was pretending like the fines were spread out equally in the EU and somehow the US complaints are baseless - when its obvious that the fines are heavily weighted towards US companies.

Whatever this is based on - OP was misrepresenting the data.

[piva00]

I don't think OP said anything about the spread of the fines amount being equal, they brought up that there are many EU-based companies whom have been levied fines, I believe you interpreted it wrongly and are bashing a non-existing argument.

US companies have been fined larger sums because their transgressions are more common, they do it repeatedly, and their global revenue is higher, there's no conspiracy here, it's exactly how the law is written.

I invite you to re-read their point:

> The vast majority of fines are towards european businesses.

Which is true, the majority of fines are towards EU-based businesses, not the majority of the amount in fines.

Again, if US-based companies with a much higher revenue and market penetration weren't breaking the laws they wouldn't be levied the higher fines.

[VikingTechGuy]

It's not fines, its damages for 1 visitor.

[burnerthrow008]

> It's not a shake down, it's the fucking law which they don't follow and have to pay fines accordingly. Every single business in the EU has to follow these laws,

That’s a lie, and you know it.

Spotify is not a “gatekeeper” according to the DMA. Why? Because there is a specific carve out for streaming businesses. German newspapers do not have to comply with the GDPR. Why? Again, because there is a specific carve out for newspapers.

These laws are specifically written so that they only apply to businesses that by an unbelievably amazing series of coincidences just happen to be those not based in the EU.

Also known as a shakedown.

[piva00]

Can you point me to the carve outs in the EU's directives? No, I'm not aware of those carve outs (and German newspapers display the GDPR notices for me all the time).

Edit: found the "carve out" for newspapers: https://data.consilium.europa.eu/doc/document/ST-6087-2021-I...

And it applies to all newspapers so there's no distinction between being German or American.

If you believe it's a shakedown maybe you are looking at this with very nationalistic eyes, if US companies cannot abide by the law it's on them, most other companies do.

And Spotify doesn't have a carve out, if you read the DMA you'll understand why streaming is not considered a gatekeeper (since it's not a walled garden).

[cess11]

"Still fits the theme that EU is using GDPR to shake down big tech it does not own."

No, the EU is trying to protect the rights of its citizens.

If they wanted to "shake down big tech" they'd just do a Turkey or India and pressure them to do their bidding in terms of censorship and information exchange.

[rafaelmn]

>If they wanted to "shake down big tech" they'd just do a Turkey or India and pressure them to do their bidding in terms of censorship and information exchange.

We are already leaning on US intelligence agencies for data and every audit finds no problem in how the US handles EU data... get real - the EU is just not in the position to pull the same move because it is not the same kind of entity or legal structure, they do tariffs and regulations/collecting fines.

[cess11]

The data protection body that gave a veneer of legality to US corporations touching EU citizen data has been defunct for a while.

[FranzFerdiNaN]

Its because American companies are much larger than most European companies in terms of revenue. And because the impact of their infringements are much larger due to the nature of their business. If Bumfuck LLC from Sweden with maybe a 1000 customers fucks up they arent impacting millions of users, unlike when Google or Meta does things.

[const_cast]

IME as an American, US companies play much more fast and loose with laws. Especially tech, which has "disrupt first, ask questions later" approach to ethics.