Prosecuting Hate: An In-Depth Look at the Zundel Trials and Why Exposing Holocaust Denial is Important

Alas, I am delivering on a promised post about Holocaust denial and the Ernst Zundel trials. It’s a bit lengthy but I hope you enjoy it!

First let me say this.  If my research has taught me one thing, it’s not that Holocaust deniers are actually smart people revising history or questioning the mainstream ideas and narratives of World War II.  Historical revisionism is actually quite a serious, and respected practice.  What Holocaust deniers are, most often (and I’m tempted to say 100% of the time), are anti-Semitic ignoramuses who refuse to see the facts in front of their face in favour of unreliable sources that feed into their need to save the face of the Nazi Party and to gain undeserved attention.  But Gabrielle, if it’s undeserved attention, why talk about it at all? Isn’t that exactly what they want?  Maybe, but you need to read this essay to find out why I argue in favour of shedding light on the disrimination.

Introduction

The Canadian trials of Holocaust denier Ernst Zundel in 1985 and 1988 provide a solid case study on the effects of judicial punishment for Holocaust denial and whether it is a positive or negative pursuit of justice. While many feel that bringing Holocaust deniers to trial provides them with too much media attention and undeserved legitimacy, it can also be argued that putting deniers on trial provides a sense of justice to the target group and also enlightens people about the absurdness of their claims. Additionally, it can be seen as a way of making the general population aware of denier activity. This prevents denial from remaining as an underground network of Anti-Semites, capable of large scale networking and dangerous activity.

This paper will utilize the Zundel trials to argue that putting major Holocaust deniers on trial is in fact effective but that certain precautions should be taken by both the court system and media outlets in the path to doing so. For this reason, the second Zundel trial was much more effective than the first. By examining a number of reliable secondary sources and primary sources from the trials themselves, this essay will demonstrate the imperative nature of shedding light on Holocaust denial. It will also argue that in order for trials to be effective, there should be requirements for expert witnesses and responsible reporting on the event. This will be seen in the comparison of the first and second trial.

Background

Holocaust denial in the Western World, unlike its eastern counterpart, is mostly a manifestation of Anti-Semitism that cannot be acceptably expressed in public forums since the end of World War II.[1] As a result of Nazi attempts at hiding their crimes, deniers have utilized the missing documents and evidence of major Holocaust crimes as a means of questioning the entire thing.[2] Like many conspiracy theories, this exemplifies how a lack of evidence is used as evidence in favour of conspiracy theorists. Additionally denial can also be seen to be rooted in German resentment, not only of their reputation after the Holocaust but of their loss of the war after being promised a position at the top of world hierarchy. Although Holocaust denial in the western world started in the 1970s, it increased significantly with the advent of the internet which allowed denial literature to become more widespread and available.[3] For Canada, this has meant grappling the fine line between restrictions on freedom of speech and protecting a population that is based on values of multiculturalism. Because of this, Canada’s policies on Holocaust denial reflect a middle ground between the German laws that are harsh and strict on deniers and the American ones that value freedom of speech over all else.[4] The two Zundel trials are a perfect example of the way Canadian laws manage this expectation.

Ernst Zundel moved to Canada in 1958 from Germany[5], and as he expressed himself in an interview, felt very disenfranchised by the way the western world viewed Germany and her actions during World War II. In his words, Germany had gotten a “raw deal”.[6] Once in Canada, Zundel worked as a successful photocopier out of Toronto for years and really only became associated with the denial movement in the 1960s when he studied under “Canada’s Hitler” Adrian Arcand.[7] By the 1970s, Zundel had opened his own publishing house, Samisdat Publishers[8], and was distributing denial literature to a worldwide audience. Zundel published many denial pieces regarding Hitler, his relations to U.F.O.s and an apparent Jewish hoax to use the Holocaust as means of making Aryans feel guilty and willing to donate money.[9]

While Zundel was able to distribute his literature for a long time without disruption, in 1983 a group of Holocaust survivors led by Sabina Citron attempted to charge Zundel in a private court case under the Human Rights Tribunal for two of his publications: Did Six Million Really Die and The War, The West and Islam.[10] However, in 1984, the Crown Attorney took over the case, making it public and charged Zundel under the “false news” law for spreading a publication that was potentially harmful to the public.[11]

Did Six Million Really Die was a pamphlet based on poor logic that argued far fewer than six million Jews died during World War II and that it could be seen as equal to any other group of causalities during the war that occurred because of bombing or collateral damage.[12] In short, the document failed to explain the extent to which Jews were targeted specifically because of their religion in a malicious and intentional way. Going further, the pamphlet stated that Jews use the Holocaust to make money and to create a homeland for themselves in Palestine.[13] The major problem with this is that it does not function as a viable reason to deny the entire Holocaust. In fact, Jews making money off of the Holocaust does not affect whether it happened or not. The document is quite large and goes on to make many unstable arguments in the attempt to justify Nazi treatment of the Jews. For example, the author (Richard Verrall) concludes that Nazis were “suspicious” of Jews because they held so many financial and media-related positions in Germany.[14] However, he gives no context as to why Jews held these positions in Nazi Germany which is based on Christians historically being forbidden from filling money lending occupations. As a result, Jews filled the positions.[15]

The first Zundel trial was incredibly publicized. As a result, Zundel utilized the media to capture attention and make it seem as though his freedom of speech was being suppressed. Although this will be discussed more heavily in a latter portion of this paper, it is important to understand that the media played into the “Zundel Jujitsu”[16], giving him major headlines that made the Holocaust seem like it had come under question. For example, in the first trial, Zundel showed up in a hard hat that read “freedom of speech” which he said was required for protection against an attacker.[17] In this way, he tried to make his audience view him as the victim in the case.

Under Judge Locke, the first court case did not take judicial notice of the Holocaust, meaning that it was not seen in the eyes of the law as a notorious event that need not be questioned.[18] Because of this, most of the trial focused on proving whether the Holocaust had happened rather than whether Ernst Zundel had done something wrong. This essay will argue that this is an ineffective use of the judicial system in punishing Holocaust denial and will point out the difficulties that arose in the prosecution of Zundel as a result. Still, the final ruling on the first court case was a fifteen month prison sentence and a three year probationary period during which time Zundel could not publicly discuss his opinion on the Holocaust because of Did Six Million Really Die.[19] The charges laid by the other publication were dropped.

In 1986, the Ontario Court of Appeals overturned the ruling, resulting in a retrial of Ernst Zundel in 1988.[20] This time, under Judge Thomas, the Holocaust was given judicial notice.[21] Because of this, the case could focus more on the damage of Zundel’s publications and not on whether the Holocaust happened or not. Additionally, the case was much less public meaning less media frenzy and fewer opportunities for Zundel to distort the basic facts of the Holocaust that historians have come to accept. Zundel was found guilty at this trial and served a nine month prison sentence.[22] Because of Zundel’s inability to debate the Holocaust and manipulate media attention at this trial, it was more sufficient.

Upon his release, Zundel continued to distribute denial material but this time online, via his website, Zundelsite.[23] In 1996, the Human Rights Council charged Zundel and demanded he stop but because the site was technically run out of Tennessee, it was not an enforceable charge.[24] However, Zundel fled to the United States to avoid trial, which as Mark Freiman notes, at least allowed Canadians to rid themselves of one of the world’s biggest Holocaust deniers and closet anti-Semites.[25] Zundel was deported from the United States back into Canada where he was denied citizenship and held in solitary confinement for three years.[26] Next, Zundel was deported to Germany in 2007 where he was found guilty under the much stricter Auschwitz Lie-Law under fourteen accounts of inciting hatred.[27]

Uncovering Hatred

A main concern expressed by academics when discussing Holocaust denial and bringing it to trial, is that it provides deniers with more attention and legitimacy than they deserve. Additionally, it exposes the non-academic public to doubts about the Holocaust that they did not know about before. Not only can a court case help to unmask many of these techniques but it can also help to hold deniers responsible for their actions. Perhaps the academic field needs to provide the non-academic world with more credit because there was no increase in Anti-Semitism or denial of the Holocaust in Canada as a result of the Ernst Zundel trials. By comparing the first and second trials however, one can understand that the second Zundel trial was overall, more effective at doing so.

A major example of the important capabilities of prosecuting Holocaust denial is seen in the results of Weimann and Winn’s Zundel trial studies.[29] In 1986, Weimann and Winn published an important article concerning the first Zundel trial that put much of the skepticism of academics to rest. Through a detailed survey handed out randomly across the country in 1985, after the first Zundel trial and sentencing, Weimann and Winn noticed a trend that showed literally no increase in Anti-Semitism or Holocaust denial legitimizing.[30] In fact, amongst those whose opinions had changed as a result of the trial, most became more stringent in their opinions against Holocaust denial. Additionally, one quarter of the followers became more sympathetic to Jews and four fifths became less sympathetic towards Germans.[31]

The first Zundel trial, as stated above however, despite its success for impact on audience, had a few road bumps that are troublesome when looking at how Holocaust denial is handled in the court room. For example, Zundel was able to call upon his own expert witnesses.[32] As such he called upon Robert Faurrisson who is a French literature expert[33] and David Irving who studied physics and political economy but never actually graduated.[34] The prosecution however, called upon Raul Hillberg, a Holocaust scholar whose doctorate was written on the topic.[35] While the differences between the two expert witnesses showed in the type of sources they used and claims they stated, putting them on equal footing in the court room is unproductive. Higher demands for expertise should be required in the court in order to ensure legitimacy. This was somewhat repaired in the second trial however.

In the second trial of Ernst Zundel, Judge Thomas had higher standards for who could present themselves as an expert witness. As such, the proceedings improved and Holocaust deniers in the case were limited in the claims they could state. An example of this can be seen in regards to Fred Leutcher. Faurrisson and Zundel called upon Leutcher, a supposed execution expert in the United States, to visit Auschwitz-Birkenau and Majdanek to assess whether gas chambers existed at these locations.[36] Leutcher came back to the court to showcase what the denial world considers a ground-breaking document. Looking at the report, which is available through Zundel’s website, one can understand the faulty methods Leutcher used in claiming there were in fact no gas chambers at these camps. For example, he starts his study with a look at current American gas chambers and the safety restrictions on them.[37] He then goes on to discuss the American gas chambers that existed during World War II, saying that had the Germans really created any, then logically, the Americans would have been consulted in regards to building them.[38] This is easily debunked for two reasons: first because the Germans were going to great lengths and utilizing the war to cover up what they were doing and second because the Americans were the enemies of the Germans during World War II and would not have shared execution tips with them. Still, the document provides a great amount of detail and scientific jargon that at times is overwhelming. Had Leutcher been allowed to present this in court, parts may have served to distort the history of the Holocaust. Fortunately, Thomas declared that Leutcher could not serve as an expert witness, nor could his document be utilized for the defense. This was because, upon research of his background, it was discovered that Leutcher in fact had very little experience with execution equipment and had lied.[39] This showed how the Canadian court system improved in the second trial of Ernst Zundel and combated providing legitimacy to Holocaust denial.

An additional way that the second trial was much more appropriate for dealing with Holocaust denial was via the use of testimonies. In the first trial, Zundel’s lawyer Douglas Christie (who is well known for defending Holocaust deniers like James Keegstra) was able to question Holocaust survivors who testified regarding their experience during the Holocaust.[40] Not only has Christie been criticized for being too harsh on the survivors with his line of questioning, but also for the amount of “hearsay” he objected to. Because of the hearsay rule, survivors could only stick to their own experiences and not speak to those of any of the people they were with who perished during the Holocaust.[41] Also, as Douglas points out, even when hearsay is overruled, it serves to break up a testimony and cause the one being testified to forget their place.[42] While the court was still successful in shedding light on Holocaust denial, the proceeding could have been improved. This example serves as a reason why.

Fortunately, in the second trial, not only was Zundel not allowed to testify, but neither did the survivors.[43] Because of the judicial notice taken, the court case focused on the damage of Zundel’s document, therefore not causing further psychological damage to the victims of the Holocaust. This enabled the public to understand the Holocaust denial occurring in their country without placing it on equal footing to the prosecution to lend it legitimacy.

In conclusion, the Zundel trials not only held Zundel accountable for his Anti-Semitic propaganda, but also exposed what he was doing to the general public. While it may be argued that this made him more important than his previously insignificant state, it allowed Canadians to understand the dangerous network of Anti-Semitic literature coming out of their country. Considering Zundel was sending his publications to forty-two countries world-wide[44] however, the first argument cannot really stand. Not only did the publicity work in the opposite direction of Zundel’s desires, but the extensive research done by the prosecution served to provide further education on the Holocaust itself.

Despite both trials being somewhat successful, the second trial was much more appropriate and successful in setting an example of the serious consequences of Holocaust denial. Requirements for testimonials, judicial note and expert witnesses improved the court proceedings, shifting focus from debate over whether the Holocaust happened or not to the actual crime committed.

Seeking Justice

The most important concern when discussing Holocaust denial and bringing the crime to court is the effect it has on the target group. In this case, the target group is mainly Jews but also extends to Romas, the disabled (both mentally and physically) and homosexuals among other minority groups who were persecuted in Nazi Germany. It also effects descendents and community members who identify with the victims. In the case of the Ernst Zundel trials, there was ample opportunity for the target group to feel persecuted. The trials alone could rehash the trauma undergone during World War II and survivor witnesses were put through lines of questions that were unfair and could cause psychological disturbance. Still, this portion of the essay will argue that for target group members, trials provide a retributive justice for those who have denied their history. Additionally it will prove that the second Zundel trial significantly minimized the potential for trauma.

The Ernst Zundel trial impacted Torontonian Jews for obvious reasons- many within the population and their ancestors fled to Canada to avoid Nazism and anti-Semitism. Having a known Anti-Semite not only in their midst but distributing publications worldwide is daunting. For this reason, it is likely that most target members would see a trial of Zundel as important despite trauma from the trial. A strong example proving this can be seen in the results of Kallen and Lam’s 1993 survey.[45] The authors surveyed 200 Jewish community members in Toronto (seeking out “the average” over community leaders) in order to gain their opinions on the trial.[46] Most felt that Zundel, although “silly” was spreading harmful messages and should be charged[47] as a result despite the fact that 80% of the surveyed group answered that they thought they had suffered as a result of the trials themselves.[48] This shows an enormous commitment to bringing deniers to justice. Also speaking to this notion is the fact that the accuser of Zundel was Sabina Citron, a Jewish community member of Toronto who sought to put a stop to the spread of denial propaganda.[49]

The changes made between the first and second trial were significant for decreasing the potential for trauma to the target groups. As previously discussed, in the first trial Zundel’s lawyer, Douglas Christie, was able to question survivor witnesses in ways that bordered on harassment. For example, he would ask them to recall the names of all the people they knew who were burned and executed in the camps.[50] This type of questioning was not only ineffective in proving Zundel innocent, it was seen as poor treatment. It also worked to prove that the revisionist presentation was a cover for blatant Anti-Semitism. Additionally, the fact that the entire Holocaust was called into question in the first trial was potentially damaging to the target group who aim to reduce Anti-Semitism and preserve memory in future generations. Finally, the first trial was damaging for its role in the media featuring many headlines that called the Holocaust into question. Although this will be discussed in the next section of this paper, it is important to note for its ability to harm the target group.

By the second trial, the court proceedings had improved tremendously and improved conditions for the target group. The judicial notice of the Holocaust meant members did not have to concern themselves with their history being questioned. Additionally, the fact that survivors no longer testified reduced the risk of harmful confrontation. Finally, the court proceedings were much more private, with fewer controversial media headlines.[51] In this way, both Zundel trials served the purpose of providing justice via a sentence against Zundel for the target group. However, the second trial was carried out in a more responsible and considerate manner that reduced trauma for the target group.

“Zundel Jujitsu”

“Zundel Jujitsu” is a term Zundel himself came up with for the way that he used the extensive media coverage during the trial to his advantage.[52] Over the course of the first trial, the Zundel cases were covered by an incredible amount of media. In fact, there were headlines about the trial almost every other day for three months.[53] However, during the second, more private trial, media coverage was stifled which limited Zundel’s ability to exploit it. By comparing the two trials, this portion of the essay will discuss the idea that in order for trials to be effective in bringing justice to the target group, the media must act responsibly and non-objectively. Additionally, its presence should be somewhat limited. Furthermore, despite the amount of media attention Zundel was able to get, this essay will continue to argue that bringing Holocaust denial to trial is important and can be effective.

According to Greenspan, the media attention that Zundel was able to receive as a result of the trials is precisely the issue with making Holocaust denial a crime.[54] However, by looking more closely, one can understand that this is a media issue and not one with the court systems themselves. Had media outlets acted more responsibly and less objectively, some of these criticisms may have been silenced. For example, during the first trial Zundel, in his typically outrageous style, showed up to court in a hard hate reading “freedom of speech” some days.[55] On the day of his sentencing he carried a cross and wore black makeup on his face[56] and still on another, Zundel showed up in a kippa, claiming to have converted to Judaism so that he may criticize Jews too.[57] This not only sparked controversy and offense for his actions, but provided the media with the sensationalism necessary for numerous headlines and television shows, often that provided no context or criticism of Holocaust denial, treating it as “late breaking news”.[58]

A possible solution to this however, does not mean silencing the media. It follows the suggestion that media outlets do not need to be objective towards things like Anti-Semitism.[59] Rather, they should take a firm and educated stance, providing criticism for the denier claims and the reasons they are worrisome- some media outlets did do this. For example, on an episode of CNN Crossfire, Zundel was interviewed in a way that sufficiently discredited him based on his claims and unmasked his tactics of circular arguments.[60]  Zundel was unsuccessful in arguing why he thought Hitler was a good leader despite a policy towards Jews that Zundel himself admitted was not a good one.[61] Had the first Ernst Zundel trial been covered in this way by all media outlets, then Zundel may not have made the statement that he gained “one million dollars in free publicity”[62].

Still, the question remains, did Zundel benefit from all the attention? In short, I would say that his “one million dollars of free publicity” simply did not exist. As a result of the first trial, Zundel was not only incarcerated and unable to publish, but he was unable to speak his mind about the Holocaust for a significant amount of time- leaving his publishing house to collapse and his presence to dwindle. Additionally, while prior to the trials he was distributing Anti-Zionist material to a worldwide audience out of Canada fairly secretly, the trials exposed him making him more susceptible to arrest and crackdown on propaganda materials. Not only did it show the general public the problems with denier claims, but it associated Zundel with a criminal network that may have created fear in some of his followers.

Furthermore, according to the study of Weimann and Winn, the reason why the media attention afforded to Zundel did not work in the way Zundel desired and academics expected was because of the audience.[63] Most often, they hypothesized, those following the trials were regular news-watchers who tend to think more critically and have more education.[64] Taking this further, much of the audience was made up of the target group who had a firm stance against Holocaust denial already established pretrial. In this way, Zundel’s media manipulation gained him no more money than he already had.

The second Zundel trial received much less media attention because it was more tightly monitored, private and most likely seen as “old news” after the first trial and after that of James Keegstra, Canada’s other well-known Holocaust denier, that same decade.[65] However, an indication of the media effects of both trials can be seen by a simple Google search. Simply typing the words ‘Ernst Zundel’ into the search engine brings up 158,000 hits of various sourcing- some of which derail his claims and others that support them.[66] However, if one tries to Google search images of Zundel’s various antics during the trial, one will come up empty handed. The web is completely free of images of Zundel carrying the cross or wearing a kippa and concentration camp garb. Without reading the works of professional historians, it is as if these antics did not take place. Shermer and Grobman in their article had to contact Zundel personally for these images.[67] So while they may have created sensationalism at the time of the trial, the effect of media coverage has not been long-lasting. What has however, is Zundel’s criminal record and time spent in jail.

Overall, the media attention paid to Ernst Zundel during his trials was not damaging enough to make the prosecution of Zundel ineffective. Although irresponsible media coverage did take place, the Weimann and Winn study shows that it did not increase anti-Semitism or Holocaust denial in Canada. Moreover, Zundel did not benefit a great deal from the media in the various ways that he claimed.

Conclusion

            Overall, the prosecution of Holocaust denial, though highly debated, is capable of supplying many positive benefits. The process of a trial and punishment for denying the Holocaust provides a sense of justice to the target group that aims to preserve the memory of a traumatic portion of their history. Additionally, it demonstrates to members that the greater public, government and judicial system care about the past and desire to work diligently against the spread of hate currently and in the future. Bringing deniers to trial also holds them accountable for what they have done, stops them from publishing propaganda (at least for the period during which they are incarcerated) and has the potential to help people understand why denial is not an appropriate, useful or logical approach to the study of the Holocaust because it is rooted in Anti-Semitism.

In the case of the two major Zundel trials in Canada, lawful action provided a showcase to debunk Holocaust denial and ‘revisionism’. The first court case, although putting the Holocaust on trial (which should not have happened), forced Christie, Zundel, and his various “expert” witnesses to put forth their arguments in a concise manner. Often this meant saying that far fewer than six million Jews died during World War II, saying that Jewish deaths were from starvation and typhus not gas chambers and claiming that these deaths were not carried out with intention by the Nazi regime. This was demonstrated in particular, with the Leutcher Report. In doing so, the defense utilized a number of very thin witness testimonies with very little historical research to back it up. Despite this reliance, the defense did not accept witness testimonies on the other side of the court case, despite being higher in volume and content. Furthermore, the trial allowed the general public to learn about the experience and education of Fred A. Leutcher, a major part of the defense team, showing that he had no credentials to pose as an execution expert. This alone, discredited many of Zundel’s Holocaust claims. Additionally, much legitimate Holocaust research was done as a result of this trial which led to further scholarship in the field.[68]

During the second trial, judicial notice was taken and media coverage was kept to a minimum. As a result, more focus was spent on assessing the harm of Zundel’s publication and unmasking his poor research rather than debating over events well known on the historical record. The result of this was a much smoother trial that easily proved Zundel as a guilty party. Furthermore, the minimal media coverage meant more responsibility in terms of reporting because there was less opportunity for Zundel to act out and manipulate the media in the ways that he did in the first trial. In this way, despite both trials being a sufficient means of confronting Holocaust denial and dealing with it in Canada, the second trial seemed to work more smoothly and provide less of a media frenzy based on profit over the actual story.

               [1] Gilbert Achar, “Assessing Holocaust Denial in Western and Arab Contexts,” Journal of Palestine Studies 14.1 (Autumn 2011): 82.

               [2]Archer, “Assessing Holocaust Denial,” 83.

               [3] Archer, “Assessing Holocaust Denial,” 83.

               [4]Marouf A. Hasian Jr., “Canadian Civil Liberties, Holocaust Denial and the Zundel Trials,” Communications and the Law 21.3 (1999): 43.

               [5]Hasian, “Canadian Civil Liberties,” 43.

               [6]”Ernst Zundel on CNN #1,” last modified October 8, 2007, http://www.youtube.com/watch?v=_y9eg0KX7-I.

               [7]Robert A. Kahn, “Rebuttal versus Unmasking: Legal Strategy in R.v. Zundel,” Patterns of Prejudice (July 2000): 34.3, 5.

               [8] Kahn, “Rebuttal versus Unmasking,” 6.

               [9] Gabriel Weimann and Conrad Winn, “The Misrepresentation of Public Opinion: The Canadian Nazi Trials and their Implications,” Political Science and Politics 19.3 (Summer 1986): 641.

               [10]Hasian, “Canadian Civil Liberties,” 43.

               [11] Hasian, “Canadian Civil Liberties,” 43.

               [12] Richard E. Harwood, Did Six Million Really Die (Toronto: Samisdat Publishers, 1974): Introduction. Accessed via, www.ihr.org/books/harwood/dsmrd01.html

*Please note that Richard E. Harwood is a pseudonym for Richard Verrall. The court case however, condemned Zundel for his participation in creating and publishing the document, not Verrall.

               [13] Harwood, Did Six Million Really Die, Introduction.

               [14] Harwood, Did Six Million Really Die, Chapter 1.

               [15] The Longest Hatred: The History of Anti-Semitism, TV Movie, directed by Rex Bloomstein (USA: 1993).

               [16] Mark Freiman, “Litigating Hate on the Internet,” Canadian Issues 0318-8442 (Summer 2006): 66.

               [17] Lawrence Douglas “The Memory of Judgement: The Law, the Holocaust, and Denial,” History and Memory 7.2 (Fall-Winter 1995): 100.

               [18] Hasian, “Canadian Civil Liberties,” 43.

               [19] Weimann and Winn, “The Misrepresentation of Public Opinion,” 642.

Kahn, “Rebuttal versus Unmasking,” 7.

               [20]Douglas, “The Memory of Judgement,” 113.

               [21] Douglas, “The Memory of Judgement,” 113.

               [22]Hasian, “Canadian Civil Liberties,” 43.

               [23] Raphael Cohen-Almager, “Freedom of Expression versus Social Responsibility: Holocaust Denial in Canada,” Journal of Mass Media Ethics 28.42 (2013): 45.

               [24] Cohen-Almager, “Freedom of Expression versus Social Responsibility,” 45.

               [25] Freiman, “Litigating Hate on the Internet,” 66.

               [26] Cohen-Almager, “Freedom of Expression versus Social Responsibility,” 45.

               [27] Cohen-Almager, “Freedom of Expression versus Social Responsibility,” 45.

               [28] Kahn, “Rebuttal versus Unmasking,” 3.

               [29] Weimann and Winn, “The Misrepresentation of Public Opinion.”

               [30] Weimann and Winn, “The Misrepresentation of Public Opinion,” 642.

               [31] Weimann and Winn, “The Misrepresentation of Public Opinion,” 642.

               [32] Douglas, “The Memory of Judgement,” 113.

               [33] “Holocaust Handbooks and Movies Presented by the Barnes Review: Robert Faurrisson,” last modified 2009-2014, http://holocausthandbooks.com/index.php?author_id=10.

               [34] “The Curious Case of David Irving (Part 1),” last modified June 5th, 2013, http://www.veteranstoday.com/2013/06/05/the-curious-case-of-david-irving-part-i/.

               [35] Hasian, “Canadian Civil Liberties,” 43.

               [36] Deborah E. Lipstadt, Denying the Holocaust: The Growing Assault on Truth and Memory,(New York: Plume Books, 1993): 162.

               [37]Fred A. Leutcher, “The Leutcher Report, The End of a Myth: A Report on the Alleged Execution Gas Chambers at Auschwitz, Birkenau and Majdanek, Poland by an Execution Equipment Expert,” http://www.solargeneral.com/library/leuchter-report.pdf, 10.

               [38]Leutcher, “The Leutcher Report,” http://www.solargeneral.com/library/leuchter-report.pdf, 39.

               [39]Lipstadt, Denying the Holocaust, 164.

               [40] Hasian, “Canadian Civil Liberties,” 43.

               [41]Douglas, “The Memory of Judgement,” 111.

               [42]Douglas, “The Memory of Judgement, 111.

               [43] Kahn, “Rebuttal versus Unmasking,” 7.

               [44] Weimann and Winn, “The Misrepresentation of Public Opinion,” 641.

               [45] Evelyn Kallen and Lawrence Lam, “Target for Hate: the impact of the Zundel and Keegstra trials on a Jewish-Canadian Audience,” Canadian Ethnic Studies 25.1 (1993).

               [46] Kallen and Lam, “Target for Hate,” 17.

               [47] Kallen and Lam, “Target for Hate,” 9.

               [48] Kallen and Lam, “Target for Hate,” 19.

               [49]Kahn, “Rebuttal versus Unmasking,” 6.

               [50] Hasian, “Canadian Civil Liberties,” 43.

               [51]Kahn, “Rebuttal versus Unmasking,” 7.

               [52] Freiman, “Litigating Hate,” 66.

               [53] Weimann and Winn, “The Misrepresentation of Public Opinion,” 642.

               [54] Edward L. Greenspan, “Should Hate Speech be a Crime?,” Queen’s University Quarterly 11.1 (Spring 2004): 81.

               [55] Douglas, “The Memory of Judgement,” 100.

               [56] Hasian, “Canadian Civil Liberties,” 43.

               [57] Cohen-Almager, “Freedom of Expression versus Social Responsibility,” 46.

               [58] Kahn, “Rebuttal versus Unmasking,” 7.

               [59] Cohen-Almager, “Freedom of Expression versus Social Responsibility,” 42.

               [60] “Ernst Zundel on CNN #1,”, http://www.youtube.com/watch?v=_y9eg0KX7-I.

               [61] “Ernst Zundel on CNN #1,”, http://www.youtube.com/watch?v=_y9eg0KX7-I

               [62] Ernst Zundel in Hasian Marouf A. Jr, “Canadian Civil Liberties, Holocaust Denial, and the Zundel Trials,” Communications and the Law 21.3, 43.

               [63] Weimann and Winn, “The Misrepresentation of Public Opinion,” 641-645.

               [64] Weimann and Winn, “The Misrepresentation of Public Opinion,” 644.

               [65] Weimann and Winn, “The Misrepresentation of Public Opinion,” 641.

               [66]”Google Search of Ernst Zundel,” March 2014.

               [67] Michael Shermer and Alex Grobman, Denying History: Who Says the Holocaust Didn’t Happen and Why do they Say it?, (California: University of California Press, 2002): 65.

[68] further scholarship in the field

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