Online Defamation in US, UK, Hong Kong and China

The Issue of Jurisdiction

The essence of the Internet is borderless. Once a user posts a message on a website or newsgroup, every Internet user all over the world can read it. Some countries might have more onerous defamation laws while some countries such as the United States have more protection on the freedom of speech and exclude the liability of ISP under certain law. For instance, if a person from Hong Kong posts a defamatory message in a U.K. hosted forum against a company from China and the forum is usually visited by many U.S. Internet users, then where should the plaintiff - the Chinese company sue the person? Is the jurisdiction valid to the law of another country? This is a problem which needs to be tackled in the traffic-speedy Internet world.