Evan Selinger and Woodrow Hartzog assert that the right to be forgotten is a catchy description of something far more realistic: enhancing obscurity of information. In this light lowering the rank of unwanted search results is effective: “Poor search visibility is … an extremely valuable obscurity protection because of the high transactional cost of finding information that isn’t easily uncovered by a simple search.” Or, as Harvard law professor Jonathan Zittrain points out, “The second page [of search results]…might as well be in Siberia”.