I literally said the environments are different. please read. What my entire point is about is that these problems are systemic and unsolvable due to human nature. SLAPPs were just a single example of the systemic issue. The primary way (IIRC) the EU addressed SLAPPs is by allowing for financial recovery for the defendant from the accuser after winning the case, this is only useful if the defendant can actually afford to run the trial to completion.

You literally cannot have a legal system that prevents the point I'm making because if you did you'd have a legal system that prevents redressing actual harm, which is fundamentally the point of a functioning legal system.

Any system that presupposes no harm is being done and rejects cases out of hand will result in unaddressed harms. Any system that actually prevents harm must have a way for a party to prove their position of harm being done. Any system that allows for a party to prove their position of harm inherently allows for the system to be abused by parties who can sink money into forcing discovery, etc.

These are just facts about the legal system that literally cannot be avoided no matter how much you try to hand wave them away with nonsense about 'standing' or trying to assert one geopolitical area vs another.

Either you have a legal system that allows for redressing harm or you have a legal system that is for punishment and protecting the state (i.e. were sovereign immunity comes from).

Since ostensibly both judicial systems in this conversation allow for a discovery phase, which often is incredibly expensive for the defending party, my original point stands that these types of laws can be abused to financially drain competition.

Again I have nothing against this law in particular beyond the problems inherent in such a policy. which in this case are minor and would not prevent me from supporting it in general; but we should be aware of the harm potential.