in france. so the analogies don't work.

http://en.wikipedia.org/wiki/Hate_speech_laws_in_France#Freedom_of_the_press

Freedom of the press
The Law on the Freedom of the Press of 29 July 1881 guarantees freedom of the press, subject to several prohibitions. Article 24 prohibits anyone from publicly inciting another to discriminate against, or to hate or to harm, a person or a group for belonging or not belonging, in fact or in fancy, to an ethnicity, a nation, a race, a religion, a sex, or a sexual orientation, or for having a handicap. The penalty for violating this prohibition is up to a year of imprisonment and a fine of up to €45,000, or either one of those, as well as the suspension of some civil rights in some cases.
Articles 32 and 33 prohibit anyone from publicly defaming or insulting a person or group for belonging or not belonging, in fact or in fancy, to an ethnicity, a nation, a race, a religion, a sex, or a sexual orientation, or for having a handicap. The penalty for defamation is up to a year of imprisonment and a fine of up to €45,000, or either one of those punishments. The penalty for insult is up to six months of imprisonment and a fine of up to €22,500, or either one of those punishments.
La loi du 29 juillet 1881 allows the public prosecutor to initiate criminal proceedings against a violator of the law either upon the complaint of a victim or upon his own initiative. A victim may choose to undertake a civil action against a violator. Such a civil action must obey rules prescribed for a criminal proceeding, and a court may assess both civil damages and criminal penalties at the same time. Article 48-1 permits civil-rights organizations to seek damages for violations of the law.