the European Convention as revealed by Bleich are different from each other and arguably cover opposite things. "The US constitution categorically upholds the value of Free Speech whereas the European Court of Human Rights Article 10 explicitly lists the reasons that free expression can be constrained." Similarly, Docherty suggests that institutionally, the US First Amendment is through the nature of the American Judicial system and the difficulty of constitutional reform affords greater protection as well as fewer restrictions on the Freedom of Speech. Whereas through the Margin of Appreciation and the reliance upon members' constitutions being sufficiently robust the Freedom of Expression within the ECtHR does not directly afford the same level of protection of expression to citizens. The main point of similarity the two sources of freedom of expression share is that they are both not absolute and can be limited, this is also enhanced through the varying criteria by which they can be restricted also being very similar. Namely, those listed in Article 10 (2) such as "…in the interests of national security, territorial integrity, or public safety, for the prevention of disorder or crime". It is this that often leads to a common belief they are one of the same by many of the population. Although it should be acknowledged as above that achieving such limitation is a point of difference between the two judicial systems and legislation. Hate Speech Hate speech is highly contextual and subjective in terms of content and victim, which makes it very difficult to legislate against on a national and especially on a multinational level. As revealed by Foster, Article 10 is applicable to all forms of speech and expressions, but the ECtHR as highlighted by Handyside V United Kingdom demands a level of tolerance and pluralism of the exercise of the same freedom of expression right of others who share views which maybe not shared by the receiver of the information or opinions. However, despite the expectancy of citizens to exercise tolerance, it may be difficult to achieve not only as stated before due to the subjective nature of offence being taken but also the complexity of the ECtHR failing to define hate speech within either Article 10 or any other convention, ruling or European wide statute to date. This could be explained through the need to provide states with a Margin of Appreciation, due to varying cultures finding offence to