The difference being that in the U.S. the government has to justify going against the clear wording of the Constitution in order to limit speech: "Congress shall make no law ...abridging the freedom of speech,..." There is no clause in there saying, "except in those cases where the government deems it necessary..." One can certainly argue about the way that the Constitution is applied, but the wording leaves no wiggle room. Actually, I would argue that the people of the U.S. have decided that they no longer care about the Constitution, they want a government that "gets things done" and have election after election voted for people who are willing to bend the Constitution until we have reached the point where the President can do what he likes as long as those responsible for following his instructions are willing to go along with it. For example, our current President has offered waivers to legal requirements that there is no legal basis for providing waivers to. He has stated that he is not going to enforce certain laws that he does not like. He has promised companies that the government will pay the penalties for not complying with certain laws where their compliance would have been politically detrimental to him. He has ordered people to pay for services that are a violation of their religious beliefs. Understand that these examples are merely to show that we have arrived at the point where the President no longer feels bound to give anything more than the most transparent lip service to the Constitution, not an indictment of this particular President. We got to this point bit by bit. This President's predecessor signed a law that he felt was unconstitutional because he felt it was politically necessary, stating at the time that he expected the Supreme Court to overturn the law.