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I’d venture to guess that students of comparative speech theory were not all too surprised by the latest shifts in social media policy, such as Mark Zuckerberg’s about-face with respect to content moderation on Meta’s platforms in early 2025.1 Silicon Valley and Brussels have been on an extended regulatory collision course for over a decade.2 In historical perspective, the fault lines are perhaps less surprising, and certainly less novel, than current tech policy commentary might suggest. The constitutional frameworks of free speech against which today’s policy debates play out have been long established on the national and supranational levels, striking a different normative balance between speech protection and permissible speech regulation.3 In Freedom of Expression: The Revolutionary Roots of American and French Legal Thought, Ioanna Tourkochoriti closely examines the foundation for understanding these constitutional frameworks, providing deep historical and philosophical groundwork for today’s speech landscape in transatlantic perspective by analyzing the U.S. and French approaches “on the proper limits to freedom of expression” (p. 6). Though she doesn’t frame her study in this way, a reader following the meanderings of modern conflicts between Silicon Valley and Brussels cannot escape the fundamental modern day implications for social media policy offered in this book. And in subsequent work analyzing the European Union’s Digital Services Act, Tourkochoriti herself astutely identifies persisting sites of contestation.4
