Note there speech wasn't criminalizes in itself. No press got prosecuted for relaying their speech. Let's not pretend restrictions on free speech are anywhere near equivalent in scale between the two countries.
Constitution of China also gives citizens freedom of speech, freedom of press etc. It's not criminalized. It's just that if you say something damaging, they will find something else that you violated for which you have to go to jail.
To outside observers, specially, to those who pay you to say those things, it is obvious that you have been framed because of what they said and they tell their media to report accordingly.
Chinese constitution says a lot, but china does not practice constitutional law: judges are not allowed to base decisions on the constitution and definitely are not allowed to use the constitution as the basis for overriding official law.
In a similar vain, china lacks rule of law. Rather they practice rule by law, where laws are used to control the public (if they want to get you, they'll find a laws you've probably broken) vs. having everyone, including officials who haven't fallen out of favor, subject evenly to them. So even westerner developed democracies aren't perfect in their practice of rule of law, but in china it isn't even a goal (like they have rejected constitutional law).
It isn't binary of course. Rule of law is a goal for western countries, it isn't for China, where the CCP has publicly said (a) constitutional law is not appropriate for China and (b) a separate independent judiciary is not appropriate for China. In that case, the CCP simply does not subscribe to rule of law as a concept appropriate for use in the country.
You are absolutely right that the de jurie restrictions are not comparable. It's difficult to imagine a fully-functioning, sensible adult who can look at the official-ish Chinese position(s) and not object.
However, it is not entirely unreasonable to compare the end results. There is definitely a chilling effect in the USA, effecting many of the very people who are best in a position to blow a whistle. And that this has been accomplished without the appearance of a draconian overreach is itself part of that chill.
These two (and other) methods of state violence against expression are worth considering when choosing a region for a cloud services provider.
> There is definitely a chilling effect in the USA
Perhaps with individual whistle blowers, but definitely not with the press. I agree the USA is nowhere near perfect, and I always fear it will become more like China rather than say much of western europe (which still is far from perfect).
> These two (and other) methods of state violence against expression are worth considering when choosing a region for a cloud services provider.
If you want to associate with a better run state for your cloud service region, you have much better options than China. Not that Alibaba is bad at all, I have friends who work there and it seems to be a decent company by Chinese standards.
Wasn't saying that the US doesn't suppress dissent in it's own ways, just that it doesn't use it's domestic surveillance capabilities to do it by, say, assigning each citizen a "patriotism score" based on their aggregate social media activity.
And I agree with jMyles that the chilling effect of it all is bad as is. Still, it could be worse.
Yes, "speech" that is illegal because it is damaging to the ruling class.
See: Snowden, Manning, Assange.