Z:gnu-www-ja-hague--417b91-Americans may turn to the Firs/en

Americans may turn to the First Amendment to protect them from foreign judgments against their speech. The draft treaty permits a court to ignore a foreign judgment that is &ldquo;manifestly incompatible with public policy.&rdquo; That is a stringent criterion, so you cannot count on it to protect you just because your conduct is legal where you are. Just what it does cover is up to the particular judge. It is unlikely to help you against broad foreign interpretations of copyright, trademarks or software patents, but U.S. courts might use it to reject outright censorship judgments.