Bill Jackson in his letter ‘Time to adopt US libel model’ argues that we should adopt one aspect of the US libel law model – namely the requirement for a claimant to prove malice in cases involving public figures – and commends that model to us.

Leaving aside the high importance of protecting reputation, which US law fails to achieve, there is, I suppose, something to commend the US model.

For a start, libel payouts by defendants in the US are six times higher per head of population than here.

Whereas an award above £50,000 is the exception in the UK, the average award in a libel action in the US is about $2.2m.

And whereas awards for general damages in the most severe libel cases in the UK are capped at £220,000, awards in the US can run into tens of millions of dollars, with one running in excess of $30m.

It was precisely because of these huge jury awards that the US Supreme Court introduced the radical requirement of proof of malice in Sullivan, for fear one American newspaper after another would be closed down by crippling awards of damages.

The American system is so awful no other country has copied it. We would be fools to do so.

Nigel Tait, Partner, Carter-Ruck, London EC4