BTW, Jeri, your line "I think I'd be happy if the US made it possible to prosecute people who deliberately lied to the public in order to manipulate them for their own gain." Is covered by your laws. Look back to the article you linked to and check out the section on the USA. The first section says -

In the United States freedom of expression is protected by the First Amendment to the United States Constitution. There are several common law exceptions including obscenity,[151][152] defamation,[151][152] incitement,[152] incitement to riot or imminent lawless action,[151][152] fighting words,[151] fraud, speech covered by copyright, and speech integral to criminal conduct; this is not to say that it is illegal, but just that the government may make it illegal.

I think Fox News etc. could well come under many of those exceptions :-)

And upon double checking I find the first section of the UK entry says -

United Kingdom citizens have a negative right to freedom of expression under the common law.[98] In 1998, the United Kingdom incorporated the European Convention, and the guarantee of freedom of expression it contains in Article 10, into its domestic law under the Human Rights Act. However there is a broad sweep of exceptions including threatening, abusive or insulting words or behavior intending or likely to cause harassment, alarm or distress or cause a breach of the peace (which has been used to prohibit racist speech targeted at individual

Now, it may just be me, but I don't understand the difference between freedom of expression being guaranteed under article 10 of the European convention and it being guaranteed under the first amendment of the US constitution. How is it a 'completely different take on free speech"?

Cheers

DtG