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Comment by nostromo | Hacker News Reader

French voters are free to censor their own internet. They aren't free to censor the internet globally.

France is free to set up their own version of the Great Firewall of China if they want to block Google.com within their borders. That's their recourse; demanding Google censor search results everywhere is not.

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Yet America demands the right a) to tax its citizens globally b) to force other countries to enforce its sanctions under risk of freezing their banks' payment systems (BNP Paribas / Russian banks), c) Hollywood inspired copyright law must be imposed on the rest of the planet (Hollywood is "free" not to sell its wares to the globe, if it doesn't like the piracy risk), d) free-market "democracy" must be imposed on unready countries lest 500 000 troops land on your doorstep, ready to wreak decades of collateral havoc (see Iraq/ISIS).

France is making a point that there is a legitimate argument to be discussed about things that happen in France not be pushed out to the rest of the planet. They may be wrong, but the debate is worth having. If Google doesn't like it, it is free to quit France, and the french will be free to punish their government for it.

I concur - this is an act of corporate imperialism on the part of Google, and it should be no surprise that - as an American company - it flaunts its ability to ignore the will of sovereign entities freely. Troubling times indeed .. I hope this will be reversed in the near future, because I think the right to be forgotten is a very human right, and should not be impinged upon by those who have nearly no other purpose than the rampant commercialization of citizens as consumers. My citizenship is more important than my function as a consumer. Google need to be taught some respect for this fact, alas ..

All I see is France trampling over other countries sovereignty. Free speech is a protected right in the US, but France is trying to exert French law over American citizens (I'm using the US as an example).

It's silly argument: if you do this for all countries, you'll be left with a tiny intersection of only the content that is not illegal in some form somewhere on earth.

I can see it as France trampling over other countries sovereignty, but I can also see it as France protecting its sovereign citizens, which is .. after all .. the Purpose of Sovereignty in the first place. So I'm not swayed by your corporatist argument that we should just negate the rights of citizenry for the sake of a clearly non-Sovereign, corporate entity - which has demonstrably profited from the mass-harvesting of social information at the personal layer.

It is indeed a gray area, but what did you expect between the extreme black and white of individual freedom and corporate control/hegemony? Some sort of simple 'bit flip'?

Alas, precisely because the bits are so easily flipped, this discussion must be continued - and it must not be being conducted, so, reactively.

I am an advocate for the right to disappear. I happen to think, having witnessed the bit flip in the positive direction - i.e. mass-surveillance as a consumer - I also wish to remind my peers that it must be recognized that it can .. also .. just as easily be turned off.

In other words, French mores on the issue should infect American mores. It would be good for other cultures, other mores, to not let it go the other way: Total Surveillance as a normative.

In this sense, perhaps yet again, the French lead the way.

Important detail: not once in my comment did I mention or hint at a corporate entity. I was merely commenting on a nation-to-nation level.

You seem to be fine with French law applying to American nationals - what do you think of sharia law applying to French nationals? How about the law-of-the-week declared by some upstart banana republic dictator? Who gets to pull the lever on global law? Where do you, fit2rule, draw the line - is it only France? Only countries where Google has operates? only western democracies? Or does every sovereign get to throw what they deem illegal into the pot?

Google do business in France, and are thus subject to French laws when doing so - especially with regard to how it interacts with French citizens. Do you not think that as a state, France has some jurisdiction over how this occurs?

And yes, I deem sovereign power more important than corporate power. Don't you?

French laws being applied in France ate fine and dandy. French laws applied worldwide? I'm with "corporate power" on that one. Someone needs to tell France to keep it's laws to itself. That is the essence of sovereignty

Apples and oranges not only between the situation, but each point you listed.

America can do whatever it wants tax-wise to its own citizens. Copyright and bank integration has to do with existing trade agreements that are peer-shared and mutually respected. Russia is free to keep its assets within its own country if it doesn't want to participate in a larger system with shared rules.

The issue here is that France is trying to apply a local law that is not mutually agreed upon with any other country, to other countries. And in doing so is creating bad precedent regarding censorship extended across borders with no recourse. I can't challenge France's law in court as a US citizen, so why should I be denied access to information at their discretion?

Your perspective is too narrow. The wider point is that not everyone agrees with America, yet by virtue of the dollar's dominance, and America's military dominance, America can force anyone to accept its point of view. Clearly no country can survive without access to the dollar-based global payments system. To pretend that Russia can merrily go on without access to it is to sit behind a convenient lie.

That is what is happening in all of my points, including (the relatively minor) point a). Recall that it is not obvious that revenue earned in a country that is not America should be taxed by America.

More generally, someone democratic needs to challenge America once in a while, arguably for America's own health.

So they point out what is wrong with your example, and you make even vaguer arguments in favor of it?

Here, your argument is even weaker because it is essentially "we give america power, and they use it".

The dollar's dominance is not america's fault, it's literally everyone else's :)

America has not militarily imposed it's will on france or any other european nation that i'm aware of in the recent past so i'm not sure you can really claim america forcing y'all to their point of view on that one.

If you think for a second that any country that has power will not use it against other countries in trade negotiations, that just seems ultra-naive to me.

"Recall that it is not obvious that revenue earned in a country that is not America should be taxed by America."

Hey, remember that time when france tried to tax all the Google revenue not earned in france by claiming google ireland has a permanent establishment in france (and then claims google owes it a billion in tax when the max google possibly earned was a total of 237 million in google france?)?

No worries though, i'm sure, unlike every other country, france wouldn't try to use it's power to force any other country or multi-national corporation to do anything. They'll only do the right thing.

France would almost certainly do exactly the same, as indeed it did once upon a time when it was briefly dominant in Europe (late 17th/18th centuries). Yet it would have been correct to speak truth to might then, just as it is now.

"Truth to might"

I think this is a bit of hyperbole.

Past that, can you point to a time in history when a utopic state of happiness and rightness ruled (IE you got what you wanted) and the world still functioned?

Your argument is too broad for the issue under discussion. What you say may be true, but the fact remains that (regardless of the underlying reason) these other countries agreed to the terms set by the US with respect to copyright, and agreed to enforce the sanctions.

The argument that France appears to be making in this case is that it doesn't need other countries to agree to its demands, its courts have jurisdiction everywhere.

I feel the difference is straightforward. The US has an interest in its world view and values being shared by the rest of the world and uses its economic power to get other countries to agree, at least in part, to enforcing that world view and values. They are not however (in general), asserting that decisions made in the US apply in other countries (except to our own citizens, wherein enforcement of the local US law is still at the discretion of the foreign nations while our citizens are within their borders).

If the US were to assert global jurisdiction for a decision made in a local (i.e., state or federal) court it would be equally unfounded. If, however, they were to negotiate with another country and use our economic advantage to get them to agree to enforcement of a particular policy, then the country has presumably weighed the pros and cons of that decision and decided it was worth the compromise. You don't have to like it, but if you skip the middle step sovereignty as a nation becomes meaningless.

> What you say may be true, but the fact remains that (regardless of the underlying reason) these other countries agreed to the terms set by the US with respect to copyright, and agreed to enforce the sanctions.

Just like people agree to pay the mob protection money.

I mean, countries could refuse to go along with things like FATCA. It would be an enconomic disaster for them when the US freezes them out, but they could do it.

Two wrongs don't make a right. France is at fault and so is the US in many of the examples you cited here, so why do you keep defending the indefensible and morally questionable policies of the French state?

The US is a bully that enforces its will worldwide via military and economic might. I don't hate the US, but I consider that statement to be fact at this point. They have an absurd tax system and use threats to get other governments to agree to enforce it.

Europe can pass whatever laws they like, and Google can ditch whatever countries they feel are not worth the hassle.

Google will tell France to go piss up a rope before they go along with this nonsense. Google would lose far more by rolling over.

A is an example of "you can do what you want to *your own citizens when it doesn't affect the sovereign rights of other countries", so it's not applicable (IE if the US started taxing french citizens, you'd have a point)

b and c are examples of mutually-agreed treaties/agreements. If france didn't want to do it, it shouldnt' have signed the treaties :)

d was a mostly-coalition force AFAIK (not my area of expertise), but let me just suggest that rules of starting/fighting wars is not quite the same as the right to be forgotten, and that this doesn't belong as an example because basically every country can be accused of starting wars to impose it's will unilaterally somewhere else. That's what war is :)

I rest my case. You're basically saying "we're strong so we'll do what we want, thanks, and you'd do the same". Fair enough, and you are right, that is the way of history. But it is also the way that empires fall. ":)"

You might be unaware of this, but FATCA does not only apply to US citizens, but to "U.S. persons for tax purposes". Me, being a German citizen, have to abide FATCA simply because I have income taxable in the US.

The limitations are severe: Since living in the US I am not allowed to hold certain financial products that I owned when living in Germany, since compliance with US law would be to costly for German institutions. In particular, citing wikipedia [1], "It requires non-US (foreign) financial institutions, such as banks, to enter into an agreement with the IRS to search through their customer databases to identify those customers suspected of being U.S. persons and to disclose the account holders' names, TINs, addresses, and the transactions of most types of accounts."

[1] https://en.wikipedia.org/wiki/Foreign_Account_Tax_Compliance...

You have income (effectively a form of residency) in two countries. How is it a surprise that you have to abide by both countries laws?

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