> For example, Germany's "incitement of popular hatred" [3] can be used to prevent newspapers from advancing the argument that migrants are disproportionately likely to commit crimes.

Bull. Shit.

Tabloids still run ridiculously xenophobic and bigoted headlines in Germany even if we're not quite at the level as e.g. UK tabloids.

Saying "there's a correlation between the refugee crisis and a rise in crimes" is protected speech in Germany. Saying "those donkey fuckers crossing our borders must be shot on sight and their children too" is hate speech.

We're talking about the kind of statements that get showcased on sites like this: https://perlen-aus-freital.tumblr.com

In the US it's acceptable for politicians calling for undesirables like Snowden or Assange to be murdered. In Germany this kind of rhetoric would land you in jail for inciting violence and instigating criminal behavior.

Also in Germany it's forbidden to bring weapons (including "defensive weapons" like shields or gasmasks) to demonstrations. In the US you have neo-nazis and antifa running into each other with riot gear and bashing each others' heads in with lengths of wood. Not to mention paramilitaries parading in camouflage with military-looking gear and firearms.

Incidentally, German riot police doesn't use military equipment and actual violent protests are usually confined to anarchists using improvised weapons to cause property damage.

> Since there is no truth defense against hate speech accusations

Again, bullshit. If you use Nazi symbology, loudly shout "gas the jews" and do the salute, you know what you're doing. Stop pretending we're talking about scientific discourse here.

This isn't about some economist or sociologist publishing troubling research findings or level-headed reporting on anything of the sort. This is about bigots venting their hatred and tabloids abusing scare tactics to sell more copies.

Those are indeed shameful examples and definitely discouraging.

Nonetheless, alone they are not enough to prove the point. I could go and find other cases for the US too.

If we look, though, at the Freedom of the Press report of Freedom without Borders, the US comes after all Western Europe countries (except Italy): https://rsf.org/en/ranking

I would have to disagree about (1). The right to be forgotten is quite important in preventing criminals from being punished twice (first by the law and then by random vigilantes). This fosters reintegration into society, which is considered an important part of our punitive system, perhaps even its primary goal.

In my opinion, this is also far beyond the "good" free speech (as in, free statement of opinion and political dissent) and into the realm of trying purposefully to do damage, by using speech in bad faith, which I think should not be free at all. Then again, e.g. cursing at police officers seems to be legal in the US as well, so I guess this is a cultural difference :)

  2. The EU can compel publishers to remove content they deem "hate speech." [2] If you look up the EU's definition of hate speech, it actually sweeps broadly into what the US would call protected speech.

The EU as an entity does not prohibit any speech. The EU, at most, publishes directives, which are implemented as laws and implementation is up to the specific countries.

Some coutries deem, for example, Holocaust denial a criminal offense. You can argue if this is good or bad. But let me assure you that Europe is not that hellhole where you not dare say anything.

England, with its insane libel laws may be an exception, but soon it's anyway no more part of the EU.

You just proved that EU is a better place to live.