The master’s thesis examines the public international law aspects of regulating major online platforms such as Google, Meta, Amazon, Apple, and Microsoft. The central hypothesis argues that the development of sustainable global regulatory compromises is possible only through the identification of common ground among different legal traditions. The study begins with an analysis of the emergence and evolution of surveillance capitalism, which is based on the monetization of users’ behavioral surplus. Such a business model raises concerns regarding manipulative techniques, the protection of privacy, individual autonomy, and power asymmetries between individuals, states, and digital platforms. The core of the thesis consists of a comparative analysis of three dominant regulatory models – the American, Chinese, and European models – and their underlying normative and philosophical foundations. The American regulatory model is grounded in the protection of freedom of speech and trust in market-based regulation. The Chinese model utilizes technology as an instrument of state control and prioritizes collective stability over individual liberty. The European model, by contrast, is rooted in the protection of fundamental individual rights. In its concluding section, the thesis addresses international forums such as the United Nations (UN), the Council of Europe, the World Trade Organization (WTO), and the Organisation for Co-operation and Development (OECD), which have attempted to establish normative foundations for digital governance, albeit with limited success. Based on the conducted analysis, the thesis confirms the initial hypothesis, concluding that effective international regulation is achievable only through a broader international consensus, grounded in the recognition of shared interests and commonalities among the regulatory approaches under consideration.
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