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Yes America isn't the UK, but in my opinion that discourse helps pander to the rasicts who feed into the debate the rhetoric that the UK is innocent or far removed from the American struggle. It also stops white people from really questioning systemic racism within their community for fear of saying the wrong thing.
Again linking Joshua Virasami who talks about the importance of solidarity with the American struggle. 'To really honour George Floyd’s passing we must situate his murder within the wider reality of racial capitalism.' - long read so brew a cuppa
Who killed smiley culture?
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It's a powerful argument, but how far do you take it? I can't say from personal experience, but I suspect that the experience of a black person in London is going to be different from the experience of a black person in, for example, Cornwall. Racism has many forms and is expressed in many different ways. Every person of colour is going to have a different personal journey, and a different personal experience, to any other.
The underlying prejudice and in-built systemic is the same though, I suspect. The stories may be different. The consequences may be different. But the underlying prejudice is the same.
The personal stories may be different. But the essential theme is the same.
Interesting take here about how importing the racial views from the USA over here actually obscures our own situation.
https://www.persuasion.community/p/please-stop-imposing-american-views