Europe's moves to rein in Google - including a court ruling this month ordering the search giant to give people a say in what pops up when someone searches their name - may be seen in Brussels as striking a blow for the little guy.
But across the Atlantic, the idea that users should be able to edit Google search results in the name of privacy is being slammed as weird and difficult to enforce at best and a crackdown on free speech at worst.
"Americans will find their searches bowdlerised [censored] by prissy European sensibilities," said Stewart Baker, former assistant secretary for policy at the US Department of Homeland Security. "We'll be the big losers. The big winners will be French ministers who want the right to have their last mistress forgotten."
California-based Google says it's still figuring out how to comply with the European Court of Justice's May 13 ruling, which says the company must respond to complaints about private information that turns up in searches. Google must then decide whether the public's right to be able to find the information outweighs an individual's right to control it - with preference given to the individual. The judgment applies to all search engines operating within the European Union.
But in practice that means Google, given that 90 per cent of all online searches there use Google's search engine. "The ruling has significant implications for how we handle takedown requests," Google spokesman Al Verney said. "This is logistically complicated, not least because of the many languages involved and the need for careful review. As soon as we have thought through exactly how this will work, which may take several weeks, we will let our users know."
There will be serious technological challenges, said US privacy lawyer David Keating."It seems aspirational, not a reality, to comply with such a standard," he said. "The reengineering necessary to implement the right to be forgotten is significant."
Google may partially automate the process, but ultimately a human will have to decide when results should be sanitised.
Johannes Caspar, who as Hamburg's commissioner for data protection acts as Germany's lead regulator of Google on privacy issues, confirmed the company was already working on an "online tool" to help people file complaints.
Because the court's ruling applies only within Europe, it will mean some fragmentation of search results. That is, Europeans will see slightly different versions of the internet compared to that seen elsewhere in the world. A worst-case scenario would be if Google decides it must err on the side of caution and removes links liberally in order to avoid lawsuits, critics of the ruling said.
Wikipedia founder Jimmy Wales, who has been an outspoken critic of the ruling, summarised it as a "technologically incompetent violation of human rights". He said it amounted to censorship, and he predicted it would ultimately be scrapped.
"The danger is that search engines now are faced with an uncertain legal future which may require them to censor all kinds of things when someone thinks it is 'irrelevant'," Wales said.
Differences between the US and Europe over privacy have never been greater, sparked by revelations in documents leaked to the media by former National Security Agency contractor Edward Snowden that the NSA secretly broke into communications on Yahoo and Google abroad and targeted overseas telecoms, including German Chancellor Angela Merkel's own cellphone.
Joel Reidenberg, visiting professor of information technology policy at Princeton University, said the ruling was not surprising. "In Europe, there is a sense that privacy and control over personal data are basic human rights," he said. In America, freedom of speech and free-market solutions tend to prevail, he said.