Jeri, I think what DtG is getting at is that the UK does not have a *completely* different take on freedom of speech, or for that matter human rights in general. I'm not sure why you say that US citizens have greater freedom of speech than those of the UK since the Wiki article you link to specifies a number of cases which have legal restraints similar to those in British law.

Human rights are not entirely absolute anywhere – they are all subject to various legal restraint in every country which recognises them. The restraints are a matter of culture (historical reasons, religious requirements etc), so we cannot expect what is allowed and what is not to be entirely equal everywhere. It doesn't make much sense for Europeans to say to Americans, or vice versa, "We have more freedoms than you." In some ways a US citizen might well have more freedom than a Brit, in other cases he or she might not. Gun ownership and international travel come to mind as obvious examples.

I do think though that the British laws regarding libel and the availability of superinjunctions are unduly restrictive and should be abolished.