In 2014, the Court of Justice of the European Union (CJEU) ruled in a case regarding the right to be forgotten in Spain that search engines
could be considered as data controllers who are obliged to remove search results that are relevant or linked to a data subject when searching by the data subject’s name (and when the conditions prescribed in European Union law are satisf ied). However, the Court did not clarify the scope of such removal in the 2014 case. In other words, the Court did not specify whether search engines should remove search results from their websites only in data subject’s country, all European Union member states, or worldwide. In 2019, the Court ruled in a case on the right to be forgotten in France, which has clarif ied such territorial scope. This article will further explore and discuss this 2019 decision of the CJEU.