"German law provides that our client is not a public figure," the lawyers for Wolfgang Werlé say in their cease-and-desist letter to the online encyclopedia. "The German courts including several Courts of Appeals, have held that our client's name and likeness cannot be used any more in publication regarding Mr. Sedlmayr's death."

Wikipedia is headquartered in the U.S., where the First Amendment trumps whatever privacy rights convicted murders have in keeping their names confidential. In fact, judges in this country typically say that that publishers have the right to post just about any truthful information that's newsworthy.

Nonetheless, the European authorities can still make trouble for the site. Wikipedia has already purged Werlé's name from its German page about Sedlmayr's death, but not the U.S. page.

A German court could order Wikipedia to pay damages for keeping Werlé's name online in the U.S. Even though a U.S. court might ultimately rule that such a judgment was unenforceable, the litigation could prove time-consuming and costly.

This isn't the first time that Europe's strong privacy laws have clashed with the U.S. First Amendment protections. Authorities in Italy recently brought criminal charges against four Google executives because a user allegedly uploaded a video of a teen with Down Syndrome. The Italian authorities allege that this clip -- which Google immediately removed upon receiving a complaint -- violated the teen's right to keep medical information private.

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