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Excellent analysis.

I have been chatting about this over the last couple of days. I’m not an expert so this is open discussion.

In the US, trans rights are, by my reading, entirely bound up with sex-based rights. US trans people have no dedicated set of rights.
And so when US feminists assert sex-based rights, it not only excludes trans people but it leaves them unprotected.

This is not the case in the UK. Trans people have a dedicated category (gender reassignment) in our equality legislation.
Protection of UK trans people in employment, housing, all the general stuff, is not dependent on being included in a sex category.
I wonder if US people interpret UK feminists defending sex-based rights and the legal exclusion of trans people from a set of those, as leaving those trans people with *no rights*. As might be the case in the US.

Does that make sense?
A very untechnical example:

In the UK, a trans person cannot legally be fired for being trans, or refused healthcare for being trans, etc. Those rights are not contingent on sex.
In the US, if trans people aren't included in sex-based rights to fair employment, healthcare, etc, they are left with no protection from discrimination for being trans.
This means that the effect of inclusion/exclusion has different outcomes in the US/UK, and that may skew the US judgement of UK "TERFs".
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