'Should all democracies maintain the same freedoms of expression simply because they are democracies? Or should the extent of free speech depend on each society's culture and history? By the end of the eighteenth century it was clear that France and the United States had created different conceptions of democracy, which, as this study masterfully demonstrates, continue to provide illuminating yet complex responses to those enduring questions.' Eric Heinze, Professor of Law and Humanities, Queen Mary University of London 'There is no one with as deep a knowledge of the French and American law and politics of freedom of expression as Ioanna Tourkochoriti. This book draws on history, culture, philosophy, and positive law to offer a persuasive account not only of how French and American freedom of expression regimes vary, but also, and more importantly, of what has led to the differences.' Frederick Schauer, David and Mary Harrison Distinguished Professor of Law, University of Virginia ' [ an] excellent study, which deserves the careful attention of historians, legal scholars, and political theorists alike.' John Warner, The Review of Politics