identical to that of England and Wales, Macau operates under a distinct framework modelled after Portuguese civil law, and most aspects of civil law in the Mainland are governed by the 2021 Civil Code of the People's Republic of China. In contrast, all areas of the Republic of China are governed by the Civil Code of the Republic of China which was originally modelled after the Japanese Six Codes system, itself primarily based on the German pandectist approach to law. China While tort law in China is generally governed by Book Seven ("Tort Liability") of the Civil Code of the People's Republic of China (CCPRC), liability for defamation is provided for in Book Four ("Personality Rights"). Article 1024 provides that "no organisation or individual may infringe upon other’s right to reputation by insultation, defamation, or the like", defining "reputation" as "a social evaluation of the moral character, prestige, talent, and credit of a person". In addition to damages, remedies for defamation may include the right to request a "correction" or the timely deletion of defamatory content. Qualified privilege for journalists and individuals acting "for public interest purposes" and such individuals "shall not bear civil liability for defamation except where one of the following situations exists: (1) he has fabricated or distorted the facts; (2) he has failed to fulfill the obligation to reasonably verify the seriously misrepresentative information provided by others; or (3) he has used insulting words and the like to degrade the other’s reputation". Article 1027 provides that, while "literary or artistic work" depicts actual people "with insulting or defamatory content" that "infringes upon another persons’ right to reputation" is considered defamation under the CCPRC, works which do "not depict a specific person" but "some patterns of the story are similar to the situation of such person" shall not constitute defamation. Republic of China Liability for defamation under the Civil Code of the Republic of China stems from article 195 which provides for tort liability in the case of certain non-pecuniary injuries, particularly "reputation", "privacy", and "personality". France While defamation law in most jurisdictions centres on the protection of individuals' dignity or reputation, defamation law in France is particularly rooted in protecting the privacy of individuals. While the broader scope of the rights protected make defamation cases easier to prove in France than, for example, in England; awards in defamation cases are significantly lower and it is common