I've already seen this happen with commercial spammers in Germany.
For a while I got a ton of really annoying spam, advertising for big name brands, but organized by some spam racket with no way to opt out and registered in some foreign country.
Some Googling led me to the trial of some German woman who was quite notorious among the anti-scammer community for running several spam rackets. People would spend a lot of time figuring out her connections between different font companies, data brokers, and whatnot.
Until one day Googling her name wouldn't give any results at all; Couldn't look up any addresses anymore, couldn't look up company registers with her name anymore, it all just came up blank with a notification on the bottom of the search results, informing me that Google removed some results due to the EU right to be forgotten.
It's very likely this woman is still running a very profitable spamming business with a side-business of selling data caches. Sure, one could argue that it's actually government agencies job to handle something like that, but these agencies also depend on search results, especially with something as obscure as the spam industry.