  It is worth noting that in Europe, SECs are viewed as “controllers of personal data,” as opposed to mere providers of a service (see, for example, Google Spain SL, Google Inc. 2013); as such, these companies, as well as ISPs that operate in EU countries, can be held responsible/liable for the content that is accessible through their services. One major difference regarding how SECs are viewed in the U.S. versus Europe came to the fore in the relatively recent debate about whether users should have the “Right to Be Forgotten,” now commonly referred to as the Right to Erasure.