The practice of “libel tourism” has developed because libel laws differ among countries. The United States, generally considered to offer the greatest freedom of speech, requires that the plaintiff prove the falsity of the statements against him, as well as malice or negligence on the part of the defendant. In the U.K., however, the burden of proof lies on the defendant to prove the truth of his statements, and a reasonable belief in their truth is not a valid defense.  

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