SPECIAL COLLECTION OF THE CASE LAW ON FREEDOM OF EXPRESSION In P.M.F. v. RCS Mediagroup S.P.A., Garante per la Protezione dei Dati Personali (2020), the Supreme Court considered that de-indexing old news articles struck the right balance in these sorts of cases, a criteria also followed by the same Court in Donlisander Communication S.R.L.S. v. S.A. (2020). The Supreme Court clarified the “dynamic” aspect of the right by explaining that the “right to be forgotten” also entails the right not to remain exposed ad libitum to an “image” that no longer represents what the individual has become throughout the time. This de-indexing approach was also followed by Turkey’s constitutional court, that held that recognized the existence of the “right to be forgotten”, and found that this right had been violated by the presence of a 17-year-old news article about an individual’s drug conviction on a newspaper’s internet archive. The case concerned a Turkish citizen (N.B.B.) who was convicted of drug related crimes in 1998. Three articles about this incident were published by a national newspaper between 1998 and 1999, and were subsequently included in an online archive. In 2013, N.B.B. requested that the The plaintiff wanted an order newspaper de-index the articles, claiming that they for the removal of webpages were outdated and harmed his reputation. The case eventually reached the Constitutional Court, which and links to public police held that the articles were outdated, served no public blotter reports of his/her arrest interest purpose, and that making them easily accesfor misdemeanors in 2013 sible online harmed N.B.B.’s reputation. which were still posted on A slightly different case in Italy produced a difthe new sites, even though ferent outcome. In Camera di Commercio, Industria, the official records were Artigianato e Agricoltura di Lecce v. Salvatore Manni, the CJEU held that access to an individual’s perexpunged or sealed. sonal data in company registers can only be limited in exceptional circumstances provided by domestic law, and after the expiry of a sufficiently long period following the dissolution of the company concerned. The case related to an Italian citizen, Mr. Salvatore Manni, who wanted to have information concerning him removed from the companies register in Italy. The information pertained to him being director and liquidator of a company that went insolvent and was later liquidated. He argued that the information in question harmed his reputation and caused his business to suffer. The CJEU concluded that there was a public interest in making information available to third parties about the constitution of companies, and the powers of persons authorized to represent them. Italy’s Supreme Court agreed with that conclusion. Relying on the preliminary ruling of the CJEU, it held that as Italian law provides no “right to be forgotten” related to information published in companies’ register, neither the authority responsible for maintaining the register nor the courts could erase, block or anonymize personal data in the register. The Superior Court of the Commonwealth of Massachusetts granted publishers’ Motion to Dismiss a similar petition in the case of G.W. v. Gannett Co.. The plaintiff wanted an order for the removal of webpages and links to public police blotter reports of his/her arrest for misdemeanors in 2013 which were still posted on the new sites, even though the official records 19