Jurisdictional Analysis Comparative Study Of Intermediary Liability Regimes Chile, Canada, India, South Korea, UK and USA in support of the Manila Principles On Intermediary Liability Version 1.0, 1 July 2015 Authors and Affiliations Jyoti Panday (Programme Officer) Centre for Internet and Society, India J. Carlos Lara (Research and Policy Manager) Derechos Digitales, Chile Kyun S Park (Professor) Korea University Law School; (Director) Open Net, Korea Kelly Kim (General Counsel) Open Net, Korea Acknowledgements The author would like to the inputs and feedback of Rishabh Dara, Jeremy Malcolm, Gabrielle Guillemin, Shradha Nigam, Elonnai Hickok, Pranesh Prakash and Sunil Abraham. Declaration of Conflicting Interests The author declares no potential conflicts of interest with respect to the research, authorship, and/or publication of this analysis. Funding Research, authorship, and/or publication of this article and the development of the Principles has been generously funded by a grant from MacArthur Foundation. Permissions The author has sought permission from the Steering Committee developing the Manila Principles and members who have contributed to this analysis. Corresponding Author Jyoti Panday, Centre for Internet and Society Top Floor, G-15 Hauz Khas New Delhi 110016 INDIA Email:
[email protected] jURISDICTIONAL ANALYSIS - MANILAPRINCIPLES.ORG 1 Abstract Governments around the world undertake speech regulation through the imposition of liability on intermediaries for third-party content, and often impose related obligations of proactive monitoring, exercising due diligence, and other such requirements. This study highlights the trends and crucial differences in existing liability regimes across Chile, Canada, India, South Korea, UK and USA. This analysis has been undertaken by the steering committee developing the Manila Principles and is aimed at supporting the development of the Manila Principles - a global civil society initiative.