UK and US at odds over defamation laws

From Dan Tench in the Guardian: Britain and the US are not shoulder to shoulder over defamation

"English libel law itself could face scrutiny in a US court, in a case brought by a US author in New York.

Rachel Ehrenfeld's Funding Evil: How Terrorism is Financed - and How to Stop It was published in 2003, and alleged that Saudi businessman Sheikh Kalid bin Mahfouz, among others, financed terrorism, a serious defamatory allegation. The book was published in the US, but 23 copies were made available for sale in the UK.

In 2004, Mahfouz won a default defamation claim against Ehrenfeld in the high court from the libel judge Mr Justice Eady. Ehrenfeld is seeking to resist the enforcement in New York of that English libel judgment...

If Ehrenfeld's action is successful, it will not only insulate her from the effects of the English libel award, but it might also constitute an effective retort to the implicit criticism of her from the English judgment and undermine the vindication Mahfouz obtained from it."