kind. A similar case that predates Dow Jones v Gutnick is Berezovsky v Forbes in England. This decision was criticised in the United States, though it mirrors similar decisions in many other jurisdictions such as England, Scotland, France, Canada and Italy. In response to the expansion of other jurisdictions' attempts to enforce judgements in cases of trans-border defamation and to a rise in domestic strategic lawsuits against public participation (SLAPPs) following the rise of the internet, the Federal and many state governments in America have adopted statutes limiting the enforceability of offshore defamation judgments and expediting the dismissal of defamation claims. American writers and publishers are shielded from the enforcement of offshore libel judgments not compliant under the SPEECH Act, which was passed by the 111th United States Congress and signed into law by President Barack Obama in 2010. It is based on the New York State 2008 Libel Terrorism Protection Act (also known as "Rachel's Law", after Rachel Ehrenfeld who initiated the state and federal laws). Both the New York state law and the federal law were passed unanimously. Christian perspective Catholic The Catholic Encyclopedia defines slander as "the attributing to another of a fault of which one knows him to be innocent". The effects of it are "a twofold malice, that which grows out of damage unjustly done to our neighbor's good name and that of lying as well. Theologians say that this latter guilt considered in itself, in so far as it is an offence against veracity, may not be grievous, but that nevertheless it will frequently be advisable to mention it in confession, in order that the extent and method of reparation may be settled." Defamation in said to be a violation of the eighth commandment: "Thou shalt not bear false witness against thy neighbor." Joseph Deharbe lists two possible reasons when one is "allowed, and even bound, to reveal them, 1. When it is for the good of the guilty person; or 2. When it is necessary for preventing a greater evil." In the Epistle of James there are two references to defamation: "If any man offend not in word, the same is a perfect man"; and again, "The tongue is indeed a little member, and boasts great things. Behold how small a fire what a great wood it kindles." (James 3:2,5) Based on these verse, the Roman Catechism makes the following statement: "from these