Electronic mass media and freedom of expression in Germany, the United States and Canada

This thesis examines the constitutional guarantee of freedom of expression as applied to electronic mass media. It compares the different approaches adopted in Germany, the United States and Canada. After an overview of freedom of expression doctrine in general and the main features of the regulation of electronic mass media the rationalization of this regulation in freedom of expression doctrine is analyzed.The focus of this analysis is how electronic mass media have changed the traditional understanding of fundamental rights and freedoms as purely negative individual guarantees. This change occasions and necessitates a closer look at governmental regulation and the role of the state, and the different conceptions of freedom of expression that can be used to justify it