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  Even mature democracies struggle with the issue of fake news. On January 1, 2018, Germany announced that it would begin to enforce a law, known as NetzDG, requiring social media sites to remove hate speech and fake news within 24 hours or face fines of up to 50 million Euros. In March 2018, the European Commission's High Level<\/g> Group on fake news and online disinformation issued a report concluding that although disinformation may not necessarily be illegal, it nevertheless is harmful to democratic values. Although ostensibly eschewing "any form of censorship, either public or private," it advocates greater self-regulation in the short term, with a long-range goal of developing a Code of Practices to encourage transparency, media literacy, diversity, the development of tools to "tackle" disinformation, and further research to monitor and assess the sources and impact of fake news. On the other hand, also in March, the Dutch Parliament voted to repudiate EUvsDisinfo.eu, a European Union website created by the East Stratcom Task Force in 2015 to report disinformation and fake news allegedly spread by Russian actors. Its Dutch opponents characterize it as a state publication that "passes judgments whether a publication in the free media contains the correct views or not. If your publication ends up in its database, you're officially labeled by the EU as a publisher or disinformation and fake news." In 1988, in a Harvard Law Review article, Judge Pierre N. Leval, then of the Southern District of New York, advocated creation<\/g> of what he called the "no-money, no-fault" libel suit. Under Leval's system, plaintiffs could sue to obtain a declaratory judgment of falsity. The fault requirements of Sullivan and its progeny would not apply, because, Leval claimed, "the sole purpose" of the Sullivan standard was to protect the press from crippling monetary awards. He also argued that these "no-money, no-fault" trials would be simpler, more efficient, less expensive, and would protect the media from inquiries into their news-gathering practices. They would provide plaintiffs with a far greater chance of vindicating their reputations, which is really what most of them want, he wrote.

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