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nse essentially reflects the constitutional guarantees of freedom of expression, since it reckons that such harsh penalties on the ISPs, who are those who communicate defamatory statements, may hinder truth, legitimate and fair commentary due to the fear created by such penalties [45] .

It is obvious that the US approach responds more readily and more effectively to the new cyber-age of the 21st century. The ISPs are enjoying no longer being charged with the impossible job of screening each and every one of their countless postings for potential defamation issues [46] . Moreover, the US pro-defendant direction assures the free flow of communication and a free interactive web where freedom of speech and freedom of expression are all important.

Yet, neither this absolute immunity structure can be deemed as the ideal solution regarding Internet libel law. A closer look at the other side of the argument leads us to the conclusion that such a ‘good Samaritan’ approach towards ISPs poses the danger of creating severe adverse effects in relation to the protection of reputation of the individual, which is the main aim of any libel law after all. Through such a pro-defendant approach, which liberates ISPs from liability for third party defamation, the plaintiffs that suffer as a result of the libellous comments of malicious Internet users will be left aside with no one to sue for damages in respect of the harms occurred [47] . Moreover, it could also be said that the Congress, by granting to ISPs absolute immunity from suit, failed to promote effectively a self-regulation environment as intended. Since through the Act the ISPs are free from liability in any event, they have no personal interest or motivation in structuring a self-regulatory model in order to prevent defamatory statements by their subscribers. It can therefore be concluded that the US approach is to be congratulated for enabling free communication within cyberspace, something that the UK has failed to pursue via its legislation; however, it cannot be complimented for leaving the individuals unprotected from serious online defamation breaches.

Another issue worth mentioning when assessing ISP liability in relation to defamation is the absence of a uniform international rule. Certainly, if a defamatory material were disseminated globally through the Internet, then the ISP would be forced to deal with several jurisdictions [48] . More significantly, whilst a plaintiff may lose a defamation claim under the US jurisdiction, at the same time he might be able to win his case in the UK. For instance, it is almost certain that America Online Inc would not have gained the same level of protection if the case had been adjudicated under UK law. Similarly, Demon Ltd would not have to pay damages to Godfrey in respect of the defamatory statement posted on its online board if it had been for the US Courts to decide the case. Consequently, the need for a uniform international solution is more than necessary especially today, where the Internet is the most popular place for people expressing their opinions.

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