15 August 2022 | With the Digital Services Act and the “Code of Practice on Disinformation”, the EU is creating a sophisticated infrastructure for the comprehensive censorship of information and opinions – outsourced to private corporations. The totalitarian control ambitions behind these plans that guest author Johannes Mosmann brings out in the analysis of these documents is reminiscent of dark, pre-democratic times.
Johannes Mosmann.* In June 2022, the EU’s Internal Market Committee approved the “Digital Services Regulation”, which has far-reaching consequences for freedom of expression. EU officials have started voicing the underlying worldview in no uncertain terms: Untruths behave like viruses, which is why good government must nurture truth as much as public health. And with the same methods: prevention of first contact with untruths, isolation of infected carriers and, in perspective, even vaccination against false opinions.
Governmental measures to combat the Corona pandemic can be divided into two categories: Assembly bans, compulsory masking, school closures or vaccination campaign were directly aimed at containing the pandemic. These were flanked by measures to enforce “reliable information” in the media and to “combat disinformation”, which created their own structural conditions at breathtaking speed, for example by establishing the “European Digital Media Observatory (EDMO)” as early as June 2020 (1) or by placing all “journalistic-editorial offerings” under state supervision for the first time in Germany by the “Medienstaatsvertrag” (States’ Media Treaty) in November 2020. (2)
By signing the “Code of Practice on Disinformation“, digital corporations committed to invest in “technological means to prioritise relevant, authentic and authoritative information in search, feeds or other auto-ranked distribution channels, where appropriate” and to “effectively review, control and limit the placement of advertising on accounts and websites owned by disinformation providers”. (3) In other words, they consented to manipulating their search algorithms, deleting content and depriving websites that published “false claims” of advertising revenue. The corporations have to report monthly to the EU Commission on how they neutralised disinformation and enforced “reliable information”.
Very few of those affected by this outsourced censorship have the financial means to defend themselves in court against deep-pocketed corporations. The artists’ group #allesaufdentisch, including many well-known German actors, tried it and sued against the deletion of their videos before the Regional Court of Cologne. The court ruled in favour of the artists. (4) Google, however, appealed and blocked further videos by the initiative a few days after the ruling. (5) Whether the latter will ultimately assert its right to freedom of expression should not matter to the “public-private partnerships” – until then, the videos will be stale anyway.
In August 2021, Neal Mohan, Youtube’s head of product, explained that the Google subsidiary had so far deleted more than one million Corona-related videos. (6) More effective than the deletions, however, has been the preferential treatment of “trusted information”. “With COVID, we rely on the expert consensus of health organisations like the CDC and WHO,” Mohan said. (7) Google did the same with its search engine hit lists.(8)
Regardless of the true intentions of those using the search engines, “trustworthy information” from governments or government-related institutions was pushed up in the ranking, knowing full well that anything that did not appear on the first three pages would hardly find a reader. Google curated the first page of its hit list in particular (9) to an unprecedented extent, cooperating with the WHO and Johns Hopkins University, but also with Jthe German Federal Ministry of Health. (10)
Playing with facts
Direct instructions from government representatives to newspaper publishers, broadcasters or news portals have thus been made largely superfluous. The natural interest in their own economic survival forced media providers to disseminate a single, monotonous message.
The “fact checkers” play an important role here. They are organised under the umbrella of the us-American Poynter Institute (11) and are paid by Facebook, among others, for identifying alleged fake news. (12)
In future, all truth-checkers are to work together in a network run by the “European Digital Media Observatory” and receive a compulsory contribution from the digital corporations. (13) “Fact checks” are thus by no means purely informative As service providers for the digital corporations fact checkers determine which opinions become visible and can spread.
At the same time, they have an opinion-forming effect in that they often only seem to respond to the claims to be verified, in order to put their own ones into the world. An example from the Bavarian public broadcaster: Their “#Faktenfuchs” answers the question of whether censorship takes place in Germany by saying that censorship is prohibited by the Basic Law. The interviewed “expert” adds that if someone is not allowed to say what they want, that is not censorship. The supposed “fact checker” then goes on to philosophise about the “limits of freedom of expression”, before finally attesting to Germany’s top position in terms of freedom of expression.
The most important message, however, is contained in the bold introductory words: “The AfD and other actors repeatedly voice the accusation that censorship is taking place in Germany. Anyone who expresses criticism of the government has their content deleted.” (14) The reader thus learns from the “fact check” of Bayrischer Rundfunk that the opinion that censorship is taking place in Germany comes from the far right, and he also would be part of the far right, if he shared it.
In fact, however, according to an Allensbach survey, more than half of Germans believe that one can no longer express opinions freely. (15) Rudolf Thiemann, President of the Association of German Magazine Publishers (VDZ), even thinks that the cooperation of the Ministry of Health with Google is a “unique and novel attack on the freedom of the press“. (16)
The communication scientist Dr. Prof. Michael Meyen from the Ludwig-Maximilians-Universität Munich is even more explicit in the left-liberal weekly ‘Der Freitag’ (own translation):
„The state is grabbing the internet – and the public is looking the other way … The state has installed censorship authorities and even received applause for it on the big stage … Freedom of expression and freedom of the media are gone. Today, politics determines what may be said in public.“ (17)
Neither the majority of Germans, nor VDZ-President Thiemann or Professor Meyen are close to the party AfD. Nevertheless, the #Faktenfuchs is not telling the untruth. He only chooses the question in such a way that a whole spectrum of opinions can be delegitimised together with the claim that is being checked.
Correctiv, a leading German fact-checker-organization, proceeds in a similar way. “Prisoner with swastika tattoos: photo does not come from Ukraine, but from Belarus in 2005” was the headline of a fact-check on 1 July 2022. (18) This is correct. However, Correctiv continues: “The photo is used as alleged evidence of neo-Nazis in Ukraine – a narrative used by Russian President Vladimir Putin to justify his war of aggression.”
The verified fact thus represents a “narrative” which, with its correction, is apparently refuted and becomes “disinformation”. In fact, however, there is no doubt that neo-Nazis are also fighting on the Ukrainian side – no matter where this particular photo was taken.
Who has the better propaganda machine?
Anyone who thinks, like Michael Meyen, that there is censorship in Germany is living dangerously. The communication scientist reports on the consequences of his statements: “I am to be muzzled according to the principle of contact guilt and possibly even removed from the university.” (19) No wonder – after all, his opinion is also considered “disinformation”. The logic behind it: When corporations censor, it is not called “censorship”, because according to one definition, censorship only comes from the state. The Federal Agency for Civic Education explains (Freudian (?) error in the original; own translation):
„The freedom of the press and of reporting from state intervention are prohibited by the prohibition of censorship in Article 5 (1) sentence 3 of the Basic Law. What is meant by this is a preliminary control of publications by state authorities. However, voluntary self-controls are permissible …” (20)
This definition completely misses the reality of life in a digitalised society. Those who want to censor today do not busy themselves with a bureaucratic “pre-control of publications”, as this may have been done in fascist or socialist systems. Rather, they engineer a “voluntary self-regulation” of those corporations that dominate the infrastructure of opinion formation and expression.
It is in the nature of things that the boundaries between the state and the private sector become blurred. Nevertheless, even the term “voluntary self-regulation” can no longer conceal the fact that this is in fact state regulation and thus, according to the “official” reading, censorship. The “Code of Practice on Disinformation” was already adopted in 2018 and originally aimed at curbing alleged Russian or pro-Russian “propaganda” against the backdrop of the Crimean crisis and Vladimir Putin’s alleged support for Donald Trump. (21)
According to the EU Commission, the pandemic then served as a “stress test” for the Code and should be used to evaluate and improve it. In June 2020, EU Vice-President Věra Jourová said:
„The COVID-19 pandemic is just a reminder about the huge problem of misinformation, disinformation and digital hoaxes. … But the job is not done. Far from it. The crisis showed us again that other State actors have powerful propaganda machines. I remember being shocked when I saw one opinion poll in Italy showing that Italians thought of China much more as a friend and Germany as an enemy. … It is high time to step up on this and not to allow others – such as China – to occupy the space.“ (22)
Then, in July 2020, EU-Commission President Ursula von der Leyen announced that her bureaucrats would be given much broader capabilities to “tackle disinformation” in the future, and “building upon actions listed in the recent communication on tackling COVID-19-related disinformation”. (23)
Within the framework of an “Action Plan for Democracy”, the experiences with the methods outlined above for gaining the upper hand over the opinion virus should first be evaluated, in order to then be incorporated into a “legislative package on digital services”. The “Code of Conduct to Combat Disinformation” should be tightened and incorporated into the planned new version of the “Digital Services Act”. At the same time, this was to provide the basis for the establishment of an infrastructure for permanent monitoring, control and moderation of the media landscape. One year later, in 2021, the EU Commission “informed” the German Bundesrat about its successes to date and its further plans. (24) Acknowledging, it first stated (own translation):
„As part of the monitoring programme, not only was a detailed overview of the measures taken to combat disinformation around COVID-19 based on the Code’s obligations obtained, but the Code was also subjected to a ‘stress test’.“
In particular, the latter had demonstrated the effectiveness of measures to “increase the visibility of reliable sources” and to “eliminate content that contains false or misleading information and may thereby cause physical harm or impair the effectiveness of public health policy…”. (25)
However, the EU Commission also noted a number of shortcomings. The term “disinformation” for them was often still too narrowly defined. It said that it should not only include false claims that were made deliberately, but any misinformation that could cause “considerable public damage if it went viral”. Also, the data provided by digital corporations is not yet “detailed enough to measure the extent to which commitments have been implemented or the impact of the measures taken.”
Therefore, the Commission finds it cannot be sure whether the “reported measures” have really been implemented across the board “in all member states or in all EU languages”. In addition, a “central register for fact-checks” is still missing, so that currently information that has been classified as false by “fact-checkers can reappear on different platforms”. And the withdrawal of advertising revenue, while proving to be an effective weapon, is not yet sufficient to deprive disseminators of “disinformation” of any revenue.
Media competence as supervised thinking
In future, all fact checkers are expected to cooperate with the “European Digital Media Observatory”. In order to prevent internet users from bypassing Google & Co. and switching to alternative search engines, a “broader participation” of smaller services should also be achieved. In order to completely “demonetarise” websites that intentionally or unintentionally publish articles with false claims, i.e. cut them off from sources of money, the Commission wants to have “electronic payment services, e-commerce platforms” and “crowdfunding/donation systems” included in their censorship network. In addition, the EU Commission demands full access to “personal data” of the readers of such articles (this one, for example) in order to study their behaviour and develop “appropriate” countermeasures. (26)
Exactly one year later, on 16 June 2022, the “Strengthened Code of Practice on Disinformation” was adopted and signed by Google, Microsoft, Avaaz and many other digital corporations. (27)
It asks Media platforms, publishers and advertisers to take steps to “avoid placing advertisements near disinformation content or in places where disinformation is repeatedly published” and “take steps to remove, block or otherwise restrict advertisements on pages and/or domains” that “disseminate harmful disinformation.” (28)
The signatories will also work with all “actors involved in the value chain of online monetisation” (29) so that the spread of disinformation “does not bring a single euro to anyone”, as EU Commissioner Breton explains. (30)
Most importantly, the signatories develop and enforce further “measures to limit the dissemination of harmful false or misleading information (depending on the service, e.g. banning, downgrading or non-recommendation of harmful false or misleading information, adapted to the severity of the impact and ‘with due regard to freedom of expression and information’) and take action against websites or actors that persistently violate these measures”. (31)
Digital corporations should also educate users by “helping them make more informed choices” and sending them “signals of trustworthiness” of content. (32) “The signatories concerned will develop and/or support or continue activities to improve media literacy and critical thinking, such as campaigns to raise public awareness across the European Union about disinformation as well as tactics used by malicious actors”.
Humans as a systemic risk
So, with the help of the digital corporations, the EU government wants to increase the “conformity or trustworthiness values” of the press. The prerequisite, of course, is that Google & Co. know what is “compliant” and “the truth”.
Therefore, the signatories must now conclude agreements with “independent fact-checking organisations” in order to “achieve nationwide fact-checking in all Member States” and provide these organisations with “an appropriate financial contribution for their work in combating disinformation.” (34) Thud, the EU does not directly fund the fact-checks, but it forces the signatory digital corporations to do so.
George Soros, Bill Gates and Pierre Omidyar, who are among the most important donors of fact checkers like Correctiv or Full Fact, (35,36) are likely to be pleased about this indirect state subsidy for their “independent” funding projects.
The “Strengthened Code of Practice on Disinformation” is now embedded, as envisaged in the “Action Plan for Democracy”, in a legislative package passed at the same time. It includes a new version of the “Digital Services Act” and the “Digital Markets Act”, which has also been fundamentally revised.
The trick is that signing the code of conduct remains formally voluntary. However, the law requires Google & Co. to do exactly what is regulated by the code of conduct. In other words, signing the code of conduct is the more convenient way to comply with the provisions of the Digital Services Act. Those who do not sign it voluntarily will be forced to take equivalent measures by the regulation. And it works like this:
Article 26 of the “Digital Services Act”, which is 324 pages long, first decrees in general terms: “Providers of very large online platforms shall identify, analyse and carefully assess any systemic risks arising from the design, including algorithmic systems, functioning and use of their services in the Union” (37) In doing so, the contact of “recipients” (meaning people) with contagious “disinformation” is classified as a “systemic risk” for the EU.
While it also seeks to better address cybercrime, child abuse and many other threats, the main objective of the legislative amendment is clearly stated: “This Regulation fully harmonises the rules applicable to intermediary services in the internal market in order to ensure a safe, predictable and trustworthy online environment in which to combat the spread of illegal content online and the societal risks that may arise from the dissemination of disinformation or other content …” (38)
Not illegal, but banned
Explicitly, digital groups shall go beyond tackling illegal content and focus on “information that, while not illegal, contributes to the systemic risks identified in this Regulation. Providers should therefore pay particular attention to how their services are used to disseminate or amplify misleading or deceptive content, including disinformation.” (39)
The Regulation not only obliges Google & Co. to assess the “systemic risk” lurking in search hits, but also to take effective “risk mitigation measures tailored to the specific systemic risks identified in accordance with Article 26…” (40)
Effective measures” enumerated include “adapting the design, features or operation of their services”, “adapting their algorithmic systems, including their systems of recommendation” and targeted measures aimed at “limiting or adapting the display of advertising in connection with the service they provide”. (41) In case of infringements, the EU Commission can impose draconian “fines of up to 6% of the company’s annual worldwide turnover in the preceding business year.” (42)
The focus of the Digital Services Act is less on individual measures than on building an infrastructure to explore, monitor and govern the digital space as such. The EU Commission wants to learn and be involved. Therefore, the digital corporations must now disclose their algorithms, provide all data and, under the direction of the EU Commission, continuously cooperate in the development of more efficient methods to eliminate “systemic risks”.
The data is brought together centrally, while at the same time a hierarchical system of “coordinators” for each member state ensures the nationwide “enforcement” of the “truth” at lower levels. (43) These “coordinators” in turn appoint “flag leaders” from the digital industry associations with whom they cooperate. (44) They also confer the title of “vetted researcher” on “independent third parties” who are supposed to receive not only anonymised but also personal user data “in real time” from the digital corporations “to detect, identify and understand systemic risks”. (45)
Emergency powers in the event of an undefined crisis
In the event of a “crisis” such as the Corona pandemic or the Ukraine war, the “rapid reaction mechanism” kicks in. In this case, Article 37 allows the EU Commission to intervene directly and require digital corporations to immediately identify and apply “specific, effective and proportionate measures such as those provided for in Article 27(1) or Article 37(2)” (46).
Article 27 contains the above-mentioned measures for “risk reduction” such as the adaptation of search algorithms or the demonetisation of unwelcome publishers, Article 37 the establishment of specific “crisis protocols” and other measures. The expression “such as” is significant: it means that in the event of a crisis, the EU Commission can also demand any other measures it might think of from the digital companies.
What is to be considered a “crisis” remains fully open to interpretation: “For the purposes of this Article, a crisis shall be deemed to have occurred when exceptional circumstances lead to a serious threat to public security or public health in the Union or in a substantial part thereof.”
Josep Borell, EU representative for foreign and security policy, makes the underlying worldview clear:
„It is really evident that the virus pandemic has been accompanied by an ‘infodemic’, by a pandemic of disinformation.“ (47)
The scientific image of the virus is transferred to social life. (48) The Codex and Ordinance also refer several times to the “viral” spread of “disinformation” and draw the comparison to the pandemic. The Corona crisis supposedly proves that opinions behave like viruses. Just as viruses invade the human body and make it sick, so do false thoughts and attitudes. Anyone who has had contact with “disinformation” carries the ‘brain virus’ and infects other people with it. Consequently, the government has to take care not only of ‘public health’ but also of ‘truth’. False opinions must be combated in the same way as viruses, namely by preventing first contact and isolating the infected carrier. That is the point of the new digital laws.
Even a “vaccination” against the mental illness of false opinion is being researched. According to a joint study by Cambridge and Yale Universities, contact with an “attenuated dose” of the “misinformation” can create “antibodies” in the recipient that strengthen the (mental) immune system against “future infections” with Fake News. (49)
Sander van der Linden, who leads the project at the Social Decision-Making Lab in Cambridge, is also co-author of a corresponding NATO study (50), which was presented to the “Special Committee on Foreign Influence on All Democratic Processes in the European Union” in November 2021. (51) The study concludes with the remarkable words:
„Finally, the ultimate goal of psychological inoculation is herd immunity: what percentage of an online community needs to be “vaccinated”, at what rate, and for how long, in order for sufficient immunity to be conferred? ... Computational models using the experimental effects obtained from the interventions described above are currently being designed to simulate population-level estimates for achieving psychological herd immunity against misinformation. After all, if enough people are vaccinated and have developed psychological antibodies, misinformation is less likely to be spread.“
Free opinion versus prohibited misinformation
It may seem that I am confusing the terms “information” and “opinion” here. In fact, the EU Commission tries to sharply separate the two. From their point of view, a claim such as that vaccinations do not protect against Corona is not an “opinion” but “misinformation” and must therefore be “removed”. Josep Borrell also sums up the EU Commission’s position particularly clearly here:
„Facts are one thing and opinions are another. Opinions are free; facts are facts.“ (52)
Accordingly, only those thoughts can be freely expressed that do not claim to relate to reality. The sphere of freedom is pushed back into the realm of subjective sensitivities. Reality, on the other hand, belongs to state-sanctioned science and its helpers from politics and the digital industry. They produce unquestionable “factual knowledge”. Therefore, there can be no freedom in all things about which science has something to say.
If one takes this point of view, the accusation of censorship seems inappropriate and freedom of opinion continues to prevail, because this “freedom of opinion” is not affected by the Digital Services Act at all. I can still say: “Vaccination scares me”, or: “I abhor war”. Just not “Corona vaccinations do more harm than good”, or: “The German government bears a share of responsibility for the Ukraine war.”
The price of freedom
As early as 1920, Walter Lippmann, inventor of neoliberalism and former director of the Council on Foreign Relations, explained how, with the emergence of democracy, humanity’s fate, for better or worse, was linked to the collective reception of facts. At the same time, however, the world is becoming more and more complex and a commonly accepted truth is thus becoming less and less likely.
As a solution, Lippmann suggested that the opinion-forming process should be preceded by an internationally operating, centrally organised “information service” that would supply the media with unquestionable factual knowledge. (53) Seen in this light, the Digital Services Act is merely the latest chapter of a very old narrative in liberal societies about the limits of freedom.
Since Lippmann, information technology has advanced rapidly. The arguments for a “Ministry of Truth”, on the other hand, have gained nothing since then. Of course, there is a difference between freedom of expression and factual knowledge. However, both are mutually dependent. All factual knowledge, before it can be understood as such, is first “only” an expression of opinion. Therefore, if opinions that are not or not yet experienced in their relation to reality are not allowed to be expressed on this basis, science stands still.
As a latest example of how vexing truth can be, the US Centers of Disease Control (CDC) in August quietly removed their previous claim that spike proteins from mRNA vaccinces do not stay in the body for extended periods of time.
One could argue that the only thing that matters is that “recognised” scientists be allowed to continue to put forward their hypotheses. But this objection overlooks three fundamental facts: First, science has always been advanced by personalities who were not only not “recognised” at the time they expressed their “opinions”, but were often even considered “heretics”.
Secondly, the unqualified opinion of laymen is not yet factual knowledge, but it is the inspirer of it. In the 1970s, for example, the German government claimed that opposition to nuclear power was based on the population’s “lack of knowledge”. Where would research into regenerative energies be today – without the corresponding dissemination of millions of “fake news” by environmentally conscious laypeople? The dissemination of knowledge in a society is therefore by no means top down in the form of instruction of the “common people” by knowledgeable elites. New knowledge may be gained in established specialised institutes – but the impulse for the corresponding research seldom originates there. Even initially unsubstantiated fears, assumptions and assertions must be possible in principle if the knowledge of a society is not to remain at the level of the current evidence.
And thirdly, prohibitions on thinking do not stop at the sciences, but the other way round: prohibitions on thinking then define what “science” is, so that all researchers outside the established mainstream are no longer counted as such.
It is no different with media reporting. The opinion that the reporter simply has to reproduce “the facts” is in fact a brave claim that has come under criticism since Kant at the latest. We do not only form our concepts from the facts, but also recognise the facts by means of our concepts. Which eyewitnesses the reporter talks to; which statements he considers relevant or ignores is guided by his concepts, which are elements of his individually formed conceptual system and depend on his “world view” and opinions.
Of course, in a free society there is always a danger that people will fall for fallacies or false claims and subscribe to opinions that are harmful to themselves or others. During the Corona pandemic, for example, dubious remedies were touted that could lead to serious health problems.
This argument against freedom of opinion is as old as iberal democratic societies. The question is precisely whether abolishing freedom of expression to protect those who might otherwise drink bleach outweighs the harm done to society in the process. In my view, there can be no doubt about what that balance would be, for the reasons given above. Therefore, I seek the solution in the opposite direction: a free society must radically rely on the individual’s power of judgement, not because it is infallible, but because only then can it develop and ever better meet reality.
If, on the other hand, we allow our power of judgement to be taken away from us by authorities and digital corporations that pre-sort “truth” and “lies” for us, if we even replace the inner experience of evidence with an external scanning of predetermined reference frameworks, then the force in us on which all freedom and all democracy, but also scientific progress, is based will die.
The common ideal of Walter Lippmann and the EU Commission ignores the reallity of existing human beings. They transfer the pre-scientific, even pre-philosophical state of consciousness of a naïve realism to a technocratic structure – perception without a concept, judgement without a judging subject, attitude without self-acquired insight.
However, thoughtless observation of external facts produces neither an objective science nor objective knowledge, but only a subjectively shaped, interest-driven half-knowledge. This is not to say that objectivity and neutrality are unattainable. But they can never be won in the trenches of one’s own “truth”, but only in the open battlefield of divergent views. Their arena is neither the EU Commission nor the fact-checking organisation, but the individual struggling for knowledge in his or her debate with others – in other words, precisely the mechanism that the EU Commission now wants to eliminate.
*Johannes Mosmann is a staff member of the ‘Institut für soziale Dreigliederung’ and managing director of the Freie Interkulturelle Waldorfschule Berlin and a freelance author.
This text is a slightly edited and translated version, supplemented by the author with the chapter “The Price of Freedom”, of an article that first appeared in German in the journal “die Drei”, issue 4.2022. I would like to thank the author and the publisher for allowing the second publication of this important text.
A German version of this text is here.
25 Op. cit., S. 5.
26 Op. cit., S. 8.
28 Op. cit., SLI 111.Walter Lippmann: Die Illusion von Wahrheit oder die Erfindung der Fake News, Edition Buchkomplizen, Frankfurt 2021. Original: „Liberty and the News, New York 1920. Vergleiche auch: W. Lippmann, Die öffentliche Meinung, Westend-Verlag 2021
29 Op. cit., Measure 3.1
31 https://digital-strategy.ec.europa.eu/de/policies/code-practice-disinformation Measure 18.2.; Bracket in the original
32 Op. cit., Commitment 22.
33 Op. cit., SLI 22.5.2.
34 Op. cit., Measure 30.1 and 30.2.
35 Vgl. https://correctiv.org/en/finances/; and https://www.theguardian.com/technology/2017/aug/08/fake-news-full-fact-software-immune-system-journalism-soros-omidyar
36 www.europarl.europa.eu/meetdocs/2014_2019/plmrep/COMMITTEES/IMCO/DV/2022/06-15/DSA_2020_0361COD_EN.pdf, Article 26
37 Op. cit., Preamble (9).
38 Op. cit., Preamble (57).
39 Op. cit., Article 27.
40 Op. cit., Article 59.
41 Op. cit., Article 59a.
42 The ominous “coordinators” are scattered throughout the text of the law, but are not specified anywhere. The only thing that is clear so far is that national coordinators are supposed to enforce the regulation against smaller platforms, websites and publishers and sanction their violations, while the EU Commission takes care of the global corporations. Cf. https://ec.europa.eu/commission/presscorner/detail/en/qanda_20_2348
43 See note 36, Article 19.
44 Op. cit., Article 31.
45 Op. cit., Article 27a.
53 Walter Lippmann: Die Illusion von Wahrheit oder die Erfindung der Fake News, Edition Buchkomplizen, Frankfurt 2021. Original: „Liberty and the News, New York 1920. Vergleiche auch: W. Lippmann, Die öffentliche Meinung, Westend-Verlag 2021