In the U. S. a public figure must show actual malice and reckless

for truth to recover damages for defamation. But how does this apply to the goverment itself, the president, and to a foreign goverment? Seditious speech against the U. S. goverment is protected under Brandenburg v. Ohio But what if for instance a Singaporian or German citizen uses a remailer in California to insult the head of state, the goverment or

Would willfully promotion of falsehood about a foreign goverment or a foreign goverment institution be protected speech? Could the Singaporian or German head of state or any goverment institution within these countries recover damages for defamation committed in the U.S. through a local SP? As far I understand it, there is two matters of relevance. 1) Sed¹tious advocacy under the Brandenburg standard. 2) Defamation precedence in which the Supreme Court ruled that a public figure has to demonstrate actual malice and reckless disregard for truth. The Supreme Court has never ruled that _all_ speech is protected unless it is

disregard the rulingparty at home? directed to incite or produce imminent lawless or

likely to incite or produce such action. Does this mean that defamation against the goverment or a foreign goverment could be subject for civil action as long the statute applied would meet the Sullivan standard?