> For many years, we've discussed the many challenges faced by countries in trying to recognize that "jurisdiction" on the internet isn't what they probably think it is. Many countries want to interpret internet jurisdiction as "if it's accessible here via the internet, it's covered by our laws." But it doesn't take much scenario planning to recognizing what a disaster would result from such an interpretation. Effectively that means that the most restrictive legislation anywhere in the world (think: China, Iran, Saudi Arabia, etc.) would apply everywhere else.
Similar articles talking about the different rulings, merits, jurisdictions in technology:
The American/Californian law is pretty clear that American officials, courts, law enforcement, etc. won't enforce the English default judgment. How it'd be handled in England, in the UK, and maybe even the EU is another story. What does England do with its own citizens that don't pay? If there's assets, I assume they can be frozen/seized with a court order. No assets? Arresting a person for a civil judgment when they don't have assets seems a bit barbaric. Foreign national from a friendly country? My initial hunch is that Arrington could go to England without a problem, but maybe not.
The more I think about it, the more it seems international civil law regarding technology and the internet is going to be a rapidly growing field the next 5-20 years. Curious as to how this plays out in theory and in real life.
http://www.hmcourts-service.gov.uk/infoabout/enforcement/ind... is a good source for England in general. Enforcing elsewhere within the UK is even difficult, never mind the EU at large, although it can be done. The normal approach against an individual is an attachment of earnings order, where the employer withholds money from salary to pay off the judgment (or if unemployed, the same thing happens from the person's benefits), but if the person has no income or assets (or, at least, no assets within the jurisdiction), there's really not very much anyone can do.
"Belgium Fines Yahoo For Protecting User Privacy On Its US Servers"
http://www.techdirt.com/articles/20090716/0405415571.shtml
> For many years, we've discussed the many challenges faced by countries in trying to recognize that "jurisdiction" on the internet isn't what they probably think it is. Many countries want to interpret internet jurisdiction as "if it's accessible here via the internet, it's covered by our laws." But it doesn't take much scenario planning to recognizing what a disaster would result from such an interpretation. Effectively that means that the most restrictive legislation anywhere in the world (think: China, Iran, Saudi Arabia, etc.) would apply everywhere else.
Similar articles talking about the different rulings, merits, jurisdictions in technology:
http://www.techdirt.com/blog.php?tag=jurisdiction
Wikipedia on jurisdiction as a general overview for curious people:
http://en.wikipedia.org/wiki/Jurisdiction
The American/Californian law is pretty clear that American officials, courts, law enforcement, etc. won't enforce the English default judgment. How it'd be handled in England, in the UK, and maybe even the EU is another story. What does England do with its own citizens that don't pay? If there's assets, I assume they can be frozen/seized with a court order. No assets? Arresting a person for a civil judgment when they don't have assets seems a bit barbaric. Foreign national from a friendly country? My initial hunch is that Arrington could go to England without a problem, but maybe not.
The more I think about it, the more it seems international civil law regarding technology and the internet is going to be a rapidly growing field the next 5-20 years. Curious as to how this plays out in theory and in real life.