The issue of the “right to be forgotten” presents a modern problem with regard to a person’s right to request search engine providers for the deletion of search results generated by entry on his/her name. In recent years, legislation introducing the right to request the deletion of personal data has been taking place in the EU and the U.S. This paper reviews the legal frameworks with regard to the right to request the deletion of personal data in the EU, the U.S. and Japan and studies whether there is a right for a natural person to request the deletion of search results on him/her from search businesses (in other words, the “right to be forgotten”) in each of these jurisdictions. In addition, the author examines the challenges of the Japanese legal system.