On September 24, 20191, the Court of Justice of the European
Union (the "CJEU") handed down its much
anticipated follow-on
judgment2 in connection with an individual's
right to have links removed from search results displayed following
a search of that individual's name on Google's search
engine.
Building on its recognition of a "right to
de-referencing" in its landmark 2014
Google Spain judgment3 (establishing the so-called
"right to be forgotten" or "RTBF"),
the CJEU now further clarified the territorial scope of such right,
and limited the de-referencing obligation to Google's search
engine websites corresponding to EU Member States, as opposed to
all domain name extensions (e.g., the obligation applies
to domain names with top-level domain ("TLDs")
corresponding to EU Member States, such as "google.fr"
for France or "google.be" for Belgium). The Court added
that Google may need to use, "where necessary", measures
effectively preventing or seriously
