The right to oblivion in Europe and in the United States: two different solutions for the same reality

Abstract

The digital right to be forgotten is treated in radically different ways in European and American Law, resulting from the fact that in European countries, a robust body of law and jurisprudence to protect the de-indexing right of citizens has been established. In contrast, in the United States, the tradition that places freedom of expression in a privileged position above all other rights is solid. These are two different points of view for the same situation that are analyzed in this research article.