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Comment by smsm42 | Hacker News Reader

This legal theory is completely nuts. This means if I write something in, say, Russian on my website, and it's accessible to people from Russia, I am now considered to be obliged to follow every whim of Putin regarding my site's contents, even if I don't ever step my foot in Russia and don't want anything to do with it? Hopefully this is just plain old corruption and not idiotic legal theory that language you use makes you subject to whatever laws any state using the same language invents, even if you reside on the other side of the planet and want nothing to do with that country.

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I'm reminded of the quote "A language is a dialect with an army and navy"

And what about publishing in English? Does the UK take precedence and the US has no standing? Or is a publisher subject to courts in both countries?

Technically, the US had no official language. It could claim jurisdiction over anything in any language.

UK courts have always held that US based publications/websites commit libel in the UK if they have a readership in the UK, irrespective or the location of the publisher.

The US doesn't enforce those judgements any more, but the UK still holds the principle.

UK libel laws are a known garbage fire. I think people in UK are starting to wake up to that and try to fix it: https://en.wikipedia.org/wiki/Defamation_Act_2013

The language is one factor of many used to determine if you're doing business in Germany. Otherwise you have loopholes where German language websites advertising in German, to Germans, accepting Euros, and shipping to German addresses, is somehow not considered to be "doing business" in Germany simply because their offices and servers happen to be hosted in the US.

Not completely nuts, but definitely an overreach.

> where German language websites advertising in German, to Germans, accepting Euros, and shipping to German addresses, is somehow not considered to be "doing business" in Germany simply because their offices and servers happen to be hosted in the US

You're saying it like it's a bad thing. If US has better laws than Germany and businesses serving Germans want to choose that jurisdiction because of it, it's "competition", not a "loophole". Otherwise another "loophole" we could find is that some Germans, seeking lower taxes and high standards of living, and more beneficial laws, may just move to US altogether, thus depriving German state of much needed tax income and stopping being subjects to German laws. We wouldn't want them to plug that "loophole", do we?

You have to pay U.S. taxes on worldwide income. The U.S. is the only country that does this, though.

That is indeed a defect of US system, and one that people should account for when they make their choices. I wish US stopped doing that (especially that the tax treaties in many cases lead to the fact that US doesn't even see any money anyway, it just produces tons of paperwork for expats).

Not quite the only, but almost.

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