Foreign Experience of Legal Regulation of Public Relations in The Field of Public Person’s Reputation

Abstract

Introduction. The article presents a comparative analysis of foreign models of legal regulation for the reputation of public figures in the context of digital technology development and contradictory judicial practice. The central research problem is the lack of a unified approach to balancing freedom of speech and reputation protection. Using the examples of Anglo-American, Continental European, and Chinese legal traditions, the study identifies various mechanisms for establishing this balance, with particular attention paid to the role of digital platforms and judicial precedents.Methodology and materials. The research is based on a comparative legal analysis of legislation and law enforcement practices in the United States, Great Britain, Germany, France, and China. The study covers key regulatory acts (the First Amendment to the U.S. Constitution, the UK Defamation Act 2013, the German NetzDG, etc.), landmark court decisions (New York Times v. Sullivan, Caroline von Hannover cases, ECHR jurisprudence), and specific regulatory measures of the People’s Republic of China. The theoretical framework incorporates the doctrines of balancing rights, “public interest,” and the “public figure” status.Results and Discussion. The study reveals that the Anglo-American model, based on the actual malice standard and measures against SLAPPs, provides the strongest protection for freedom of expression. Continental Europe demonstrates a mixed approach with elements of criminal liability and the influence of ECHR practice. The Chinese system subordinates reputation protection to the interests of the state and society, employing extensive censorship tools. Based on the identified differences, measures for the digital environment are proposed: increasing algorithm transparency, promoting media literacy, and establishing simplified procedures for online disputes.Conclusion. The practical significance of the work lies in developing guidelines for improving national regulation: establishing clear criteria for harm, ensuring procedural efficiency in online disputes, and creating mechanisms to prevent the abuse of censorship. The integration of best practices is recognized as a promising direction for achieving a sustainable balance between freedom of speech and reputation protection.