Case law makes a big difference here. Germany allows a number of significant exceptions and limitations to freedom of expression, while the right is closer to absolute in the USA.

• In the USA, photographing people in public places and publishing those photographs without permission is legal, and cannot be made illegal without changing the constitution. It is mostly illegal to publish photographs of people without permission in Germany, even if they were taken in public.
• Making true statements about a person, even if they're about something intimate or intended to diminish the person's social standing is legal in the USA unless there's a specific obligation of confidentiality, such as between a doctor and patient. Germany punishes releasing intimate information and presenting information in a way that encourages discrimination.
• Insults that do not amount to false statements of fact are protected speech in the USA. Insults are a crime in Germany.
• Hate speech is protected in the USA and criminal in Germany.
• Making false statements about history is protected in the USA. Holocaust denial and the like is criminal in Germany.

So no, Germany does not have a right to free speech in the sense that the USA does. One significant structural difference is that the US constitution expresses it as a negative right: it starts with "Congress shall make no law" and lists several topics the government may not regulate. The German Grundgesetz establishes positive rights to both freedom of expression and dignity, implying that the government must actively protect both and resolve conflicts between them.

Yeah, but the US sense of "free speech" is that everyone can say "Heil Hitler" on the Internet, but the media isn't allowed to say anything bad about the President under threat of being banned from the White House. It's a very particular sense of "Free Speech" that protects neo-nazis but bans late-night comedians.

If it's still unclear, don't worry, J.D.Vance will be on another of his lecture tours of Europe to explain it all again soon enough.

The right to free speech in USA is quite strong and superseds most restrictions. Even opinions are treated as protected speech and libel/slander requires proving intent as well as prior knowledge that the information is false.

Compared to that, most countries with a right to speech come with responsibility and have restrictions (specially against religious/incendiary/hate speech or a mix of them as well as falsehoods such as Holocaust denial) on what you can do with your speech.

In USA, one (specially the 'right' ones) can basically go "I'm not touching you" and get into someone's face in name of speech while that is a clear incursion into ones private space in other countries

UK is in shambles and then you call it out😂