Then there's whether even if Trump won a case in the USA, the judgment could be enforced in the UK. There's no reciprocal arrangement so he'd have to get the UK courts to enforce a judgment - and they would only enforce quantifiable damages (what did the libel actually cost him?) not punitive damages. There would be other legal hurdles - plus - this would be a beggar for the Tories and Reform - the UK could argue that under the European Court of Human Rights it would be against principles of free speech.
This from the Commissioner for Human Rights is now extensively quoted in the European Court's judgment. It derives from things like Macdonalds suing protestors for libel - and a Russian state company suing a media company for libel, but applying this to Trump's pattern of behaviour would be interesting.
“SLAPPs: lawsuits with an intimidating effect (Strategic Litigation Against Public Participation)
The Annual Report of the Council of Europe Platform to promote the protection of journalism and safety of journalists highlights groundless legal actions by powerful individuals or companies that seek to intimidate journalists into abandoning their investigations. In some cases, the threat of bringing such a suit, including through letters sent by powerful law firms, was enough to bring about the desired effect of halting journalistic investigation and reporting.
This problem goes beyond the press. Public watchdogs in general are affected. Activists, NGOs, academics, human rights defenders, indeed all those who speak out in the public interest and hold the powerful to account might be targeted. SLAPPs are typically disguised as civil or criminal claims such as defamation or libel and have several common features.
First, they are purely vexatious in nature. The aim is not to win the case but to divert time and energy, as a tactic to stifle legitimate criticism. Litigants are usually more interested in the litigation process itself than the outcome of the case. The aim of distracting or intimidating is often achieved by rendering the legal proceedings expensive and time-consuming. Demands for damages are often exaggerated.
Another common quality of a SLAPP is the power imbalance between the plaintiff and the defendant. Private companies or powerful people usually target individuals, alongside the organisations they belong to or work for, as an attempt to intimidate and silence critical voices, based purely on the financial strength of the complainant.
…
Member states therefore have a positive obligation to secure the enjoyment of the rights enshrined in Article 10 of the Convention: not only must they refrain from any interference with the individual’s freedom of expression, but they are also under a positive obligation to protect his or her right to freedom of expression from any infringement, including by private individuals. …”.
Starmer explaining European Human Rights law to Trump would be real "fly on the wall" stuff.
