Holocaust denial

in the Holocaust during World War II. Holocaust denial often includes the following claims: that Nazi Germany's Final Solution was aimed only at deporting Jews from the Reich, but that it did not include the extermination of Jews; that Nazi authorities did not use extermination camps and gas chambers to mass murder Jews; and that the actual number of Jews killed was significantly (typically an order of magnitude) lower than the historically accepted figure of 5 to 6 million. Scholars use the term "denial" to describe the views and methodology of Holocaust deniers in order to distinguish them from legitimate historical revisionists, who challenge orthodox interpretations of history using established historical methodologies. Holocaust deniers generally do not accept the term denial as an appropriate description of their activities, and use the term revisionism instead. The methodologies of Holocaust deniers are often based on a predetermined conclusion that ignores overwhelming historical evidence to the contrary. Most Holocaust denial claims imply, or openly state, that the Holocaust is a hoax arising out of a deliberate Jewish conspiracy to advance the interest of Jews at the expense of other peoples. For this reason, Holocaust denial is generally considered to be an antisemitic conspiracy theory, is frequently criticized, and is illegal in several countries. Terminology and etymology: Holocaust deniers prefer to refer to their work as historical revisionism, and object to being referred to as "deniers". Scholars consider this misleading, since the methods of Holocaust denial differ from those of legitimate historical revision. Legitimate historical revisionism is explained in a resolution adopted by the Duke University History Department, November 8, 1991, and reprinted in Duke Chronicle, November 13, 1991 in response to an advertisement produced by Bradley R Smith's Committee for Open Debate on the Holocaust: That historians are constantly engaged in historical revision is certainly correct; however, what historians do is very different from this advertisement. Historical revision of major events ... is not concerned with the actuality of these events; rather, it concerns their historical interpretation – their causes and consequences generally. In 1992 Donald L. Niewyk gave some examples of how legitimate historical revisionism—the re-examination of accepted history and its updating with newly discovered, more accurate, or less-biased information—may be applied to the study of the Holocaust as new facts emerge to change the historical understanding of it: With the main features of the Holocaust clearly visible to all but the willfully blind, historians have turned their attention to aspects of the story for which the evidence is incomplete or ambiguous. These are not minor matters by any means, but turn on such issues as Hitler's role in the event, Jewish responses to persecution, and reactions by onlookers both inside and outside Nazi-controlled Europe. In contrast, the Holocaust denial movement bases its approach on the predetermined idea that the Holocaust, as understood by mainstream historiography, did not occur. Sometimes referred to as "negationism", from the French term négationnisme introduced by Henry Rousso, Holocaust deniers attempt to rewrite history by minimizing, denying or simply ignoring essential facts. Koenraad Elst writes: Negationism means the denial of historical crimes against humanity. It is not a reinterpretation of known facts, but the denial of known facts. The term negationism has gained currency as the name of a movement to deny a specific crime against humanity, the Nazi genocide on the Jews in 1941–45, also known as the holocaust (Greek: complete burning) or the Shoah (Hebrew: disaster). Negationism is mostly identified with the effort at re-writing history in such a way that the fact of the Holocaust is omitted. Background: staking a claim on post-war Holocaust historiography- Efforts to conceal the historical record: German efforts: While the Second World War was still underway, the Nazis had already formed a contingency plan that in case of defeat they would carry out the total destruction of German records. Historians have documented evidence that as Germany's defeat became imminent and Nazi leaders realized they would most likely be captured and brought to trial, great effort was made to destroy all evidence of mass extermination. Heinrich Himmler instructed his camp commandants to destroy records, crematoria, and other signs of mass extermination. As one of many examples, the bodies of the 25,000 mostly Latvian Jews whom Friedrich Jeckeln and the soldiers under his command had shot at Rumbula (near Riga) in late 1941 were dug up and burned in 1943. Similar operations were undertaken at Belzec, Treblinka and other death camps. In the infamous Posen speeches of October 1943 such as the one on October 4, Himmler explicitly referred to the extermination of the Jews of Europe and further stated that the genocide must be permanently kept secret: I also want to refer here very frankly to a very difficult matter. We can now very openly talk about this among ourselves, and yet we will never discuss this publicly. Just as we did not hesitate on June 30, 1934, to perform our duty as ordered and put comrades who had failed up against the wall and execute them, we also never spoke about it, nor will we ever speak about it. Let us thank God that we had within us enough self-evident fortitude never to discuss it among us, and we never talked about it. Every one of us was horrified, and yet every one clearly understood that we would do it next time, when the order is given and when it becomes necessary. I am now referring to the evacuation of the Jews, to the extermination of the Jewish people. French collaboration in archive destruction: In occupied France, the situation with respect to preserving war records was not much better, partly as a result of French state secrecy rules dating back to well before the war aimed at protecting the French government and the state from embarrassing revelations, and partly to avoid culpability. For example, at Liberation, the Prefecture of Police destroyed nearly all of the massive archive of Jewish arrest and deportation. Efforts to preserve the historical record- During the war: One of the earliest efforts occurred in France during the war, where Drancy internment camp records were carefully preserved and turned over to the new French Bureau of Veterans and War Victims; which however then held them in secret refusing to release copies later, even to the CDJC. In 1943, Isaac Schneersohn, anticipating the need for a center to document and preserve the memory of the persecution for historical reasons and also support claims post-war, gathered together 40 representatives from Jewish organizations in Grenoble which was under Italian occupation at the time in order to form a centre de documentation. Exposure meant the death penalty, and as a result little actually happened before liberation. Serious work began after the center moved to Paris in late 1944 and was renamed the Center of Contemporary Jewish Documentation (CDJC). Immediate post-war period: In 1945, General Dwight D. Eisenhower, Supreme Allied Commander, anticipated that someday an attempt would be made to recharacterize the documentation of Nazi crimes as propaganda and took steps against it: The same day I saw my first horror camp. It was near the town of Gotha. I have never been able to describe my emotional reactions when I first came face to face with indisputable evidence of Nazi brutality and ruthless disregard of every shred of decency. Up to that time I had known about it only generally or through secondary sources. I am certain however, that I have never at any time experienced an equal sense of shock. I visited every nook and cranny of the camp because I felt it my duty to be in a position from then on to testify at first hand about these things in case there ever grew up at home the belief or assumption that "the stories of Nazi brutality were just propaganda". Some members of the visiting party were unable to go through with the ordeal. I not only did so but as soon as I returned to Patton's headquarters that evening I sent communications to both Washington and London, urging the two governments to send instantly to Germany a random group of newspaper editors and representative groups from the national legislatures. I felt that the evidence should be immediately placed before the American and the British publics in a fashion that would leave no room for cynical doubt. Eisenhower, upon finding the victims of the death camps, ordered all possible photographs to be taken, and for the German people from surrounding villages to be ushered through the camps and even made to bury the dead. He wrote the following to General Marshall after visiting a German internment camp near Gotha, Germany: The visual evidence and the verbal testimony of starvation, cruelty and bestiality were so overpowering as to leave me a bit sick. In one room, where they there were piled up twenty or thirty naked men, killed by starvation, George Patton would not even enter. He said that he would get sick if he did so. I made the visit deliberately, in order to be in a position to give first-hand evidence of these things if ever, in the future, there develops a tendency to charge these allegations merely to "propaganda". Nuremberg trials: The Nuremberg trials took place in Germany in 1945-1946. The stated aim was to dispense justice in retribution for atrocities of the German government. This Allied intention to administer justice post-war was first announced in 1943 in the Declaration on German Atrocities in Occupied Europe and reiterated at the Yalta Conference and at Berlin in 1945. While the intention was not specifically to preserve the historical record of the Holocaust, some of the core documents required to prosecute the cases were provided to them by the CDJC, and much of the huge trove of archives were then transferred to the CDJC after the trials and became the core of future Holocaust historiography. The Nuremberg trials were important historically, but the events were still very recent, television was in its infancy and not present, and there was little public impact. There were isolated moments of limited public awareness from Hollywood films such as The Diary of Anne Frank (1959) or the 1961 Judgment at Nuremberg which had some newsreel footage of actual scenes from liberated Nazi concentration camps including scenes of piles of naked corpses laid out in rows and bulldozed into large pits, which was considered exceptionally graphic for the time. Public awareness changed when the Eichmann trial riveted the world's attention fifteen years later. Trial of Adolf Eichmann: In 1961, the Israeli government captured Adolf Eichmann in Argentina and brought him to Israel to stand trial for war crimes. Chief prosecutor Gideon Hausner's intentions were not only to demonstrate Eichmann's guilt personally but to present material about the entire Holocaust, thus producing a comprehensive record. The Israeli government arranged for the trial to have prominent media coverage. Many major newspapers from all over the globe sent reporters and published front-page coverage of the story. Israelis had the opportunity to watch live television broadcasts of the proceedings, and videotape was flown daily to the United States for broadcast the following day. History and development of Holocaust denial after World War II- Harry Elmer Barnes: Harry Elmer Barnes, at one time a mainstream American historian, assumed a Holocaust-denial stance in his later years. Between World War I and World War II, Barnes became an anti-war writer and a leader in the historical revisionism movement. Starting in 1924, the American worked closely with the Centre for the Study of the Causes of the War, a German government-funded think tank whose sole purpose was to disseminate the official government position that Germany was the victim of Allied aggression in 1914 and that the Versailles Treaty was morally invalid. Headed by Major Alfred von Wegerer, a völkisch activist, the organization portrayed itself as a scholarly society, but historians later described it as "a clearinghouse for officially desirable views on the outbreak of the war." Following World War II, Barnes became convinced that allegations made against Germany and Japan, including the Holocaust, were wartime propaganda used to justify the United States' involvement in World War II. Barnes claimed there were two false claims made about World War II, namely that Germany started the war in 1939, and the Holocaust, which Barnes claimed did not happen. In his 1962 pamphlet, Revisionism and Brainwashing, Barnes claimed that there was a "lack of any serious opposition or concerted challenge to the atrocity stories and other modes of defamation of German national character and conduct". Barnes argued that there was "a failure to point out the atrocities of the Allies were more brutal, painful, mortal and numerous than the most extreme allegations made against the Germans". He claimed that in order to justify the "horrors and evils of the Second World War", the Allies made the Nazis the "scapegoat" for their own misdeeds. Barnes cited the French Holocaust denier Paul Rassinier, whom Barnes called a "distinguished French historian" who had exposed the "exaggerations of the atrocity stories". In a 1964 article, "Zionist Fraud", published in the American Mercury, Barnes wrote: "The courageous author Rassinier lays the chief blame for misrepresentation on those whom we must call the swindlers of the crematoria, the Israeli politicians who derive billions of marks from nonexistent, mythical and imaginary cadavers, whose numbers have been reckoned in an unusually distorted and dishonest manner." Using Rassinier as his source, Barnes claimed that Germany was the victim of aggression in both 1914 and 1939, and that reports of the Holocaust were propaganda to justify a war of aggression against Germany. Beginnings of the modern denial movement: In 1961, a protégé of Barnes, David Hoggan published Der Erzwungene Krieg (The Forced War) in West Germany, which claimed that Germany had been the victim of an Anglo-Polish conspiracy in 1939. Though Der Erzwungene Krieg was primarily concerned with the origins of World War II, it also down-played or justified the effects of Nazi antisemitic measures in the pre-1939 period.[40] For example, Hoggan justified the huge one billion Reich-mark fine imposed on the entire Jewish community in Germany after the 1938 Kristallnacht as a reasonable measure to prevent what he called "Jewish profiteering" at the expense of German insurance companies and alleged that no Jews were killed in the Kristallnacht (in fact, 91 German Jews were killed in the Kristallnacht). Subsequently, Hoggan explicitly denied the Holocaust in 1969 in a book entitled The Myth of the Six Million, which was published by the Noontide Press, a small Los Angeles publisher specializing in antisemitic literature. In 1964, French historian Paul Rassinier published The Drama of the European Jews. Rassinier was himself a concentration camp survivor (he was held in Buchenwald for having helped French Jews escape the Nazis), and modern-day deniers continue to cite his works as scholarly research that questions the accepted facts of the Holocaust. Critics argued that Rassinier did not cite evidence for his claims and ignored information that contradicted his assertions; he nevertheless remains influential in Holocaust denial circles for being one of the first deniers to propose that a vast Zionist/Allied/Soviet conspiracy faked the Holocaust, a theme that would be picked up in later years by other authors. The publication of Arthur Butz's The Hoax of the Twentieth Century: The case against the presumed extermination of European Jewry in 1976; and David Irving's Hitler's War in 1977 brought other similarly inclined individuals into the fold. Butz was a tenured associate professor of electrical engineering at Northwestern University. In December 1978 and January 1979, Robert Faurisson, a French professor of literature at the University of Lyon, wrote two letters to Le Monde claiming that the gas chambers used by the Nazis to exterminate the Jews did not exist. A colleague of Faurisson, Jean-Claude Pressac, who initially shared Faurisson's views, later became convinced of the Holocaust's evidence while investigating documents at Auschwitz in 1979. He published his conclusions along with much of the underlying evidence in his 1989 book, Auschwitz: Technique and operation of the gas chambers. Henry Bienen, the former president of Northwestern University, has described Arthur Butz's view of the Holocaust as an "embarrassment to Northwestern". In 2006, sixty of Butz's colleagues from the Department of Electrical Engineering and Computer Science faculty signed a censure describing Butz's Holocaust denial as "an affront to our humanity and our standards as scholars". The letter also called for Butz to "leave our Department and our University and stop trading on our reputation for academic excellence". Institute for Historical Review: In 1978 Willis Carto founded the Institute for Historical Review (IHR), an organization dedicated to publicly challenging the commonly accepted history of the Holocaust. The IHR sought from the beginning to establish itself within the broad tradition of historical revisionism, by soliciting token supporters who were not from a neo-Nazi background such as James J. Martin and Samuel Edward Konkin III, and by promoting the writings of French socialist Paul Rassinier and American anti-war historian Harry Elmer Barnes, in an attempt to show that Holocaust denial had a base of support beyond neo-Nazis. The IHR republished most of Barnes's writings, which had been out of print since his death. While it included articles on other topics and sold books by mainstream historians, the majority of material published and distributed by IHR was devoted to questioning the facts surrounding the Holocaust. In 1980, the IHR promised a $50,000 reward to anyone who could prove that Jews were gassed at Auschwitz. Mel Mermelstein wrote a letter to the editors of the LA Times and others including The Jerusalem Post. The IHR wrote back, offering him $50,000 for proof that Jews were, in fact, gassed in the gas chambers at Auschwitz. Mermelstein, in turn, submitted a notarized account of his internment at Auschwitz and how he witnessed Nazi guards ushering his mother and two sisters and others towards (as he learned later) gas chamber number five. Despite this, the IHR refused to pay the reward. Represented by public interest attorney William John Cox, Mermelstein subsequently sued the IHR in the Superior Court of Los Angeles County for breach of contract, anticipatory repudiation, libel, injurious denial of established fact, intentional infliction of emotional distress, and declaratory relief (see case no. C 356 542). On October 9, 1981, both parties in the Mermelstein case filed motions for summary judgment in consideration of which Judge Thomas T. Johnson of the Superior Court of Los Angeles County took "judicial notice of the fact that Jews were gassed to death at the Auschwitz Concentration Camp in Poland during the summer of 1944," judicial notice meaning that the court treated the gas chambers as common knowledge, and therefore did not require evidence that the gas chambers existed. On August 5, 1985, Judge Robert A. Wenke entered a judgment based upon the Stipulation for Entry of Judgment agreed upon by the parties on July 22, 1985. The judgment required IHR and other defendants to pay $90,000 to Mermelstein and to issue a letter of apology to "Mr. Mel Mermelstein, a survivor of Auschwitz-Birkenau and Buchenwald, and all other survivors of Auschwitz" for "pain, anguish and suffering" caused to them. In the "About the IHR" statement on their website, the IHR states, "The IHR does not 'deny' the Holocaust. Indeed, the IHR as such has no 'position' on any specific event.... The IHR does not necessarily agree with the content or outlook of posted or distributed on the IHR website, and presentations given at IHR meetings and conferences." One example of a Holocaust denialist's view that was published by the IHR is the transcript of the speech made by the Lutheran pastor Herman Otten at the Ninth IHR Conference (1989), in which he says, There is no dispute over the fact that large numbers of Jews were deported to concentration camps and ghettos, or that many Jews died or were killed during World War II. Revisionist scholars have presented evidence, which "exterminationists" have not been able to refute, showing that there was no German program to exterminate Europe's Jews, and that the estimate of six million Jewish wartime dead is an irresponsible exaggeration. The Holocaust – the alleged extermination of some six million Jews (most of them by gassing) – is a hoax and should be recognized as such by Christians and all informed, honest and truthful men everywhere. Commentators and historians have noted the misleading nature of statements by the IHR that they are not Holocaust deniers. Paul Rauber writes that: The question of whether the IHR denies the Holocaust appears to turn on IHR's Humpty-Dumpty word game with the word Holocaust. According to Mark Weber, associate editor of the IHR's Journal of Historical Review now Director of the IHR, "If by the 'Holocaust' you mean the political persecution of Jews, some scattered killings, if you mean a cruel thing that happened, no one denies that. But if one says that the 'Holocaust' means the systematic extermination of six to eight million Jews in concentration camps, that's what we think there's not evidence for." That is, IHR doesn't deny that the Holocaust happened; they just deny that the word 'Holocaust' means what people customarily use it for. According to British historian of Germany Richard J. Evans: Like many individual Holocaust deniers, the Institute as a body denied that it was involved in Holocaust denial. It called this a 'smear' which was 'completely at variance with the facts' because 'revisionist scholars' such as Faurisson, Butz 'and bestselling British historian David Irving acknowledge that hundreds of thousands of Jews were killed and otherwise perished during the Second World War as a direct and indirect result of the harsh anti-Jewish policies of Germany and its allies'. But the concession that a relatively small number of Jews were killed was routinely used by Holocaust deniers to distract attention from the far more important fact of their refusal to admit that the figure ran into the millions, and that a large proportion of these victims were systematically murdered by gassing as well as by shooting. Bradley Smith and the Committee for Open Debate on the Holocaust: In 1987, Bradley R. Smith, a former media director of the Institute for Historical Review, founded the Committee for Open Debate on the Holocaust (CODOH). In the United States, CODOH has repeatedly tried to place advertisements questioning whether the Holocaust happened, especially in college campus newspapers, which have not always been rejected. Bradley Smith has sought other avenues to promote Holocaust denial – with little success. On September 8, 2009, the Harvard Crimson school paper ran a paid ad from Bradley R Smith. It was quickly criticized and an apology was issued from the editor, claiming it was a mistake. Smith referred to his tactics as the CODOH campus project. He says, "I don't want to spend time with adults anymore, I want to go to students. They are superficial. They are empty vessels to be filled." "What I wanted to do was I wanted to set forth three or four ideas that students might be interested in, that might cause them to think about things or to have questions about things. And I wanted to make it as simple as possible, and to set it up in a way that could not really be debated." Holocaust deniers have placed "Full page advertisements in college and university newspapers, including those of Brandeis University, Boston College, Pennsylvania State University, and Queens College. Some of these ads arguing that Holocaust never happened ran without comment; others generated op-ed pieces by professors and students." James Keegstra: In 1984, James Keegstra, a Canadian high-school teacher, was charged under the Canadian Criminal Code for "promoting hatred against an identifiable group by communicating anti-Semitic statements to his students". During class, he would describe Jews as a people of profound evil who had "created the Holocaust to gain sympathy." He also tested his students in exams on his theories and opinion of Jews. Keegstra was charged under s 281.2(2) of the Criminal Code (now s 319(2), which provides that "Every one who, by communicating statements, other than in private conversation, wilfully promotes hatred against any identifiable group" commits a criminal offence. He was convicted at trial before the Alberta Court of Queen's Bench. The court rejected the argument, advanced by Keegstra and his lawyer, Doug Christie, that promoting hatred is a constitutionally protected freedom of expression as per s 2(b) of the Canadian Charter of Rights and Freedoms. Keegstra appealed to the Alberta Court of Appeal. That court agreed with Keegstra, and he was acquitted. The Crown then appealed the case to the Supreme Court of Canada, which rule by a 4-3 majority that promoting hatred could be justifiably restricted under s 1 of the Charter. The Supreme Court restored Keegstra's conviction. He was fired from his teaching position shortly afterwards. Zündel trials: The Toronto-based photo retoucher Ernst Zündel operated a small-press called Samisdat Publishers, which published and distributed Holocaust-denial material such as Did Six Million Really Die? by Richard Harwood (a pseudonym of Richard Verrall – a British neo-Nazi). In 1985, he was tried in R. v. Zundel and convicted under a "false news" law and sentenced to 15 months imprisonment by an Ontario court for "disseminating and publishing material denying the Holocaust". The Holocaust historian Raul Hilberg was a witness for the prosecution at the 1985 trial. Zündel's conviction was overturned in an appeal on a legal technicality, leading to a second trial in 1988, in which he was again convicted. The 1988 trial included, as witnesses for the defense, Fred A. Leuchter, David Irving and Robert Faurisson. The pseudo-scientific Leuchter report was presented as a defense document and was published in Canada in 1988 by Zundel's Samisdat Publishers and, in Britain, in 1989 by Irving's Focal Point Publishing. In both of his trials, Zündel was defended by Douglas Christie and Barbara Kulaszka. His conviction was overturned in 1992 when the Supreme Court of Canada declared the "false news" law unconstitutional. Zündel has a website, web-mastered by his wife Ingrid, which publicises his viewpoints. In January 2002, the Canadian Human Rights Tribunal delivered a ruling in a complaint involving his website, in which it was found to be contravening the Canadian Human Rights Act. The court ordered Zündel to cease communicating hate messages. In February 2003, the American INS arrested him in Tennessee, USA, on an immigration violations matter, and few days later, Zündel was sent back to Canada, where he tried to gain refugee status. Zündel remained in prison until March 1, 2005, when he was deported to Germany and prosecuted for disseminating hate propaganda. On February 15, 2007, Zündel was convicted on 14 counts of incitement under Germany's Volksverhetzung law, which bans the incitement of hatred against a portion of the population, and given the maximum sentence of five years in prison. Ernst Nolte: The German philosopher and historian Ernst Nolte, starting in the 1980s, advanced a set of theories, which though not denying the Holocaust appeared to flirt with Holocaust denial as a serious historical argument. In a letter to the Israeli historian Otto Dov Kulka of December 8, 1986, Nolte criticized the work of the French Holocaust denier Robert Faurisson on the ground that the Holocaust did occur, but went on to argue that Faurisson’s work was motivated by what Nolte claimed were the admirable motives of sympathy towards the Palestinians and opposition to Israel. In his 1987 book Der europäische Bürgerkrieg (The European Civil War), Nolte claimed that the intentions of Holocaust deniers are "often honourable", and that some of their claims are "not obviously without foundation". Nolte himself, though he has never denied the occurrence of the Holocaust, has claimed that the Wannsee Conference of 1942 never happened, and that the minutes of the conference were post-war forgeries done by "biased" Jewish historians designed to discredit Germany. The British historian Ian Kershaw has argued that Nolte was operating on the borderlines of Holocaust denial with his implied claim that the "negative myth" of the Third Reich was created by Jewish historians, his allegations of the domination of Holocaust scholarship by "biased" Jewish historians, and his statements that one should withhold judgment on Holocaust deniers, whom Nolte takes considerable pains to stress are not exclusively Germans or fascists. In Kershaw's opinion, Nolte is attempting to imply that perhaps Holocaust deniers are on to something. In a 1990 interview, Nolte implied that there was something to the Leuchter report: "If the revisionists Holocaust deniers and Leuchter among them have made it clear to the public that even 'Auschwitz' must be an object of scientific inquiry and controversy then they should be given credit for this. Even if it finally turned out that the number of victims was even greater and the procedures were even more horrific than has been assumed until now." In his 1993 book Streitpunkte (Points of Contention), Nolte praised the work of Holocaust deniers as superior to "mainstream scholars". Nolte wrote that "radical revisionists have presented research which, if one is familiar with the source material and the critique of the sources, is probably superior to that of the established historians of Germany". In a 1994 interview with Der Spiegel magazine, Nolte stated "I cannot rule out the importance of the investigation of the gas chambers in which they looked for remnants of the chemical process engendered by Zyklon B", and that "'Of course, I am against revisionists, but Fred Leuchter's 'study' of the Nazi gas ovens has to be given attention, because one has to stay open to 'other' ideas." The British historian Richard J. Evans in his 1989 book In Hitler's Shadow expressed the view that Nolte’s reputation as a scholar was in ruins as a result of these and other controversial statements on his part. The American historian Deborah Lipstadt in a 2003 interview stated: Historians such as the German Ernst Nolte are, in some ways, even more dangerous than the deniers. Nolte is an anti-Semite of the first order, who attempts to rehabilitate Hitler by saying that he was no worse than Stalin; but he is careful not to deny the Holocaust. Holocaust-deniers make Nolte's life more comfortable. They have, with their radical argumentation, pulled the center a little more to their side. Consequently, a less radical extremist, such as Nolte, finds himself closer to the middle ground, which makes him more dangerous. Mayer controversy: In 1988, the American historian Arno J. Mayer published a book entitled Why Did the Heavens Not Darken?, which did not explicitly deny the Holocaust, but lent support to Holocaust denial by stating that most people who died at Auschwitz were the victims of "natural causes" such as disease, not gassing. Mayer also cited the works of Holocaust deniers Arthur Butz and Paul Rassinier in his book's bibliography. Critics such as Lucy Dawidowicz criticized Mayer's citation of deniers, and argued that his statements about Auschwitz were factually incorrect. Holocaust expert Robert Jan van Pelt has noted that Mayer's book is as close as a mainstream historian has ever come to supporting Holocaust denial. Holocaust deniers such as David Irving have often cited Mayer’s book as one reason for embracing Holocaust denial. Though Mayer has been often condemned for his statement about the reasons for the Auschwitz death toll, his book does not deny the use of gas chambers at Auschwitz, as Holocaust deniers often claim. Some mainstream Holocaust historians have labeled Mayer a denier. The Israeli historian Yehuda Bauer wrote that Mayer "popularizes the nonsense that the Nazis saw in Marxism and Bolshevism their main enemy, and the Jews unfortunately got caught up in this; when he links the destruction of the Jews to the ups and downs of German warfare in the Soviet Union, in a book that is so cocksure of itself that it does not need a proper scientific apparatus, he is really engaging in a much more subtle form of Holocaust denial". Defenders of Mayer argue that his statement that "Sources for the study of the gas chambers at once rare and unreliable" has been taken out of context, particularly by Holocaust deniers. Michael Shermer and Alex Grobman observe that the paragraph from which the statement is taken asserts that the SS destroyed the majority of the documention relating to the operation of the gas chambers in the death camps, which is why Mayer feels that sources for the operation of the gas chambers are "rare" and "unreliable". Ken McVay and alt.revisionism: Ken McVay, an American resident in Canada, was disturbed by the efforts of organizations like the Simon Wiesenthal Center to suppress the speech of the Holocaust deniers, feeling that it was better to confront them openly than to try to censor them. On the Usenet newsgroup alt.revisionism he began a campaign of "truth, fact, and evidence", working with other participants on the newsgroup to uncover factual information about the Holocaust and counter the arguments of the deniers by proving them to be based upon misleading evidence, false statements, and outright lies. He founded the Nizkor Project to expose the activities of the Holocaust deniers, who responded to McVay with personal attacks, slander, and death threats. David Irving and the Lipstadt libel case: Deborah Lipstadt's 1993 book Denying the Holocaust sharply criticized various Holocaust deniers, including British author David Irving, for deliberately misrepresenting evidence to justify their preconceived conclusions. In 1996 Irving filed a libel suit against Lipstadt and her publisher, Penguin Books. American historian Christopher Browning, an expert witness for the defense, wrote a comprehensive essay for the court summarizing the voluminous evidence for the reality of the Holocaust, and under cross-examination, effectively countered all of Irving's principal arguments to the contrary. Cambridge historian Richard J. Evans, another defense expert witness, spent two years examining Irving's writings, and confirmed his misrepresentations, including evidence that he had knowingly used forged documents as source material. The judge, Justice Charles Gray, ultimately delivered a long and decisive verdict in favor of Lipstadt that referred to Irving as a "Holocaust denier" and "right-wing pro-Nazi polemicist." In February 2006 Irving was convicted in Austria, where Holocaust denial is illegal, for a speech he had made in 1989 in which he denied the existence of gas chambers at Auschwitz. Irving was aware of the outstanding arrest warrant, but chose to go to Austria anyway "to give a lecture to a far-right student fraternity". Although he pleaded guilty to the charge, Irving said he had been "mistaken", and had changed his opinions on the Holocaust. "I said that then, based on my knowledge at the time, but by 1991 when I came across the Eichmann papers, I wasn't saying that anymore and I wouldn't say that now. The Nazis did murder millions of Jews." Irving served 13 months of a 3-year sentence in an Austrian prison, including the period between his arrest and conviction, and was deported in early 2007. The episode sparked intense international debate over the limits of freedom of speech. Upon hearing of Irving's sentence, Lipstadt said, "I am not happy when censorship wins, and I don't believe in winning battles via censorship.... The way of fighting Holocaust deniers is with history and with truth." According to CNN, upon Irving's return to the UK, he "vowed to repeat views denying the Holocaust that led to his conviction" stating he felt "no need any longer to show remorse" for his Holocaust views. Recent developments and trends: In February 1995 a Japanese magazine named Marco Polo, a 250,000-circulation monthly published by Bungei Shunju, ran a Holocaust denial article by physician Masanori Nishioka which stated, The 'Holocaust' is a fabrication. There were no execution gas chambers in Auschwitz or in any other concentration camp. Today, what are displayed as 'gas chambers' at the remains of the Auschwitz camp in Poland are a post-war fabrication by the Polish communist regime or by the Soviet Union, which controlled the country. Not once, neither at Auschwitz nor in any territory controlled by the Germans during the Second World War, was there 'mass murder of Jews' in 'gas chambers.' The Los Angeles-based Simon Wiesenthal Center instigated a boycott of Bungei Shunju advertisers, including Volkswagen, Mitsubishi, and Cartier. Within days, Bungei Shunju shut down Marco Polo and its editor, Kazuyoshi Hanada, quit, as did the president of Bungei Shunju, Kengo Tanaka. In Turkey, in 1996, the Islamic preacher Harun Yahya distributed thousands of copies of a book which was originally published the previous year, entitled Soykırım Yalanı ("The Holocaust Lie") and mailed unsolicited texts to American and European schools and colleges. The publication of Soykırım Yalanı sparked much public debate. This book claims, "what is presented as Holocaust is the death of some Jews due to the typhus plague during the war and the famine towards the end of the war caused by the defeat of the Germans." In March 1996, a Turkish painter and intellectual, Bedri Baykam, published a strongly worded critique of the book in the Ankara daily newspaper Siyah-Beyaz ("Black and White"). A legal suit for slander was brought against him. During the trial in September, Baykam exposed the real author of the book as Adnan Oktar. The suit was withdrawn in March 1997. In France, Holocaust denial became more prominent in the 1990s as négationnisme, though the movement has existed in ultra-left French politics since at least the 1960s, led by figures such as Pierre Guillaume (who was involved in the bookshop La Vieille Taupe during the 1960s). Recently, elements of the extreme far right in France have begun to build on each other's negationist arguments, which often span beyond the Holocaust to cover a range of antisemitic views, incorporating attempts to tie the Holocaust to the Biblical massacre of the Canaanites, critiques of Zionism, and other material fanning what has been called a "conspiratorial Judeo-phobia" designed to legitimize and "banalize" antisemitism. In Belgium in 2001, Roeland Raes, the ideologue and vice-president of one of the country's largest political parties, the Vlaams Belang (formerly named Vlaams Blok, Flemish Bloc), gave an interview on Dutch TV where he cast doubt over the number of Jews murdered by the Nazis during the Holocaust. In the same interview he questioned the scale of the Nazis' use of gas chambers and the authenticity of Anne Frank's diary. In response to the media assault following the interview, Raes was forced to resign his position but vowed to remain active within the party. Three years later, the Vlaams Blok was convicted of racism and chose to disband. Immediately afterwards, it legally reformed under the new name Vlaams Belang (Flemish Interest) with the same leaders and the same membership. Holocaust denial in the Arab world: Denials of the Holocaust have been promoted by various Middle Eastern figures and media. Holocaust denial is sponsored by some Middle Eastern governments, including Iran and Syria. Prominent Arab figures from the Middle East have rarely made publicized visits to Auschwitz—Israel's Arab community being the exception. In 2010, Hadash MK Mohammed Barakeh visited, following a previous visit of two other Arab-Israeli lawmakers, and a group of about 100 Arab-Israeli writers and clerics in 2003. Individuals from the Syrian government, the Palestinian Authority, and a number of Palestinian groups have all engaged in various aspects of Holocaust denial. In 2006 Robert Satloff writing in The Washington Post, reported that "A respected Holocaust research institution recently reported that Egypt, Qatar and Saudi Arabia all promote Holocaust denial and protect Holocaust deniers." Hamas leaders have promoted Holocaust denial; Abdel Aziz al-Rantissi held that the Holocaust never occurred, that Zionists were behind the action of Nazis, and that Zionists funded Nazism. A press release by Hamas in April 2000 decried "the so-called Holocaust, which is an alleged and invented story with no basis". In August 2009, Hamas refused to allow Palestinian children to learn about the Holocaust, which it called "a lie invented by the Zionists" and referred to Holocaust education as a "war crime". Nasser told a German newspaper in 1964 that "no person, not even the most simple one, takes seriously the lie of the six million Jews that were murdered in the Holocaust." The thesis of the 1982 doctoral dissertation of Mahmoud Abbas, a co-founder of Fatah and president of the Palestinian National Authority, was "The Secret Connection between the Nazis and the Leaders of the Zionist Movement". In his 1983 book The Other Side: the Secret Relationship Between Nazism and Zionism based on the dissertation, Abbas denied that that six million Jews had died in the Holocaust; dismissing it as a "myth" and a "fantastic lie". At most, he wrote, 890,000 Jews were killed by the Germans. Abbas claimed that the number of deaths has been exaggerated for political purposes. "It seems that the interest of the Zionist movement, however, is to inflate this figure of Holocaust deaths so that their gains will be greater. This led them to emphasize this figure six million in order to gain the solidarity of international public opinion with Zionism. Many scholars have debated the figure of six million and reached stunning conclusions—fixing the number of Jewish victims at only a few hundred thousand." In his March 2006 interview with Haaretz, Abbas stated, "I wrote in detail about the Holocaust and said I did not want to discuss numbers. I quoted an argument between historians in which various numbers of casualties were mentioned. One wrote there were 12 million victims and another wrote there were 800,000. I have no desire to argue with the figures. The Holocaust was a terrible, unforgivable crime against the Jewish nation, a crime against humanity that cannot be accepted by humankind. The Holocaust was a terrible thing and nobody can claim I denied it." While acknowledging the existence of the Holocaust in 2006 and 2014, Abbas has defended the position that Zionists collaborated with the Nazis to perpetrate it. In 2012, Abbas told Al Mayadeen, a Beirut TV station affiliated with Iran and Hezbollah, that he "challenges anyone who can deny that the Zionist movement had ties with the Nazis before World War II". Surveys conducted by Sammy Smooha of the University of Haifa found that the fraction of Israeli Arabs denying that millions of Jews were murdered by the Nazis increased from 28% in 2006 to 40% in 2008. Smooha commented: In Arab eyes disbelief in the very happening of the Shoah is not hate of Jews (embedded in the denial of the Shoah in the West) but rather a form of protest. Arabs not believing in the event of Shoah intend to express strong objection to the portrayal of the Jews as the ultimate victim and to the underrating of the Palestinians as a victim. They deny Israel's right to exist as a Jewish state that the Shoah gives legitimacy to. Arab disbelief in the Shoah is a component of the Israeli-Palestinian conflict, unlike the ideological and anti-Semitic denial of the Holocaust and the desire to escape guilt in the West. Holocaust denial in Iran: Former Iranian President Mahmoud Ahmadinejad frequently denied the Holocaust, formally 'questioning' the reliability of the historical evidence, although he on occasion confirmed belief in it. In a December 2005 speech, Ahmadinejad said that a legend was fabricated and had been promoted to protect Israel. He said: "They have fabricated a legend, under the name of the Massacre of the Jews, and they hold it higher than God himself, religion itself and the prophets themselves.... If somebody in their country questions God, nobody says anything, but if somebody denies the myth of the massacre of Jews, the Zionist loudspeakers and the governments in the pay of Zionism will start to scream." The remarks immediately provoked international controversy as well as swift condemnation from government officials in Israel, Europe, and the United States. All six political parties in the German parliament signed a joint resolution condemning this Holocaust denial. In contrast, Hamas political leader Khaled Mashaal described Ahmadinejad's comments as "courageous" and stated, "Muslim people will defend Iran because it voices what they have in their hearts, in particular the Palestinian people." In the United States, the Muslim Public Affairs Council condemned Ahmadinejad's remarks. In 2005 the Egyptian Muslim Brotherhood leader, Mohammed Mahdi Akef, denounced what he called "the myth of the Holocaust" in defending Iranian president Mahmoud Ahmadinejad's denial of the Holocaust. On December 11, 2006, the Iranian state-sponsored "International Conference to Review the Global Vision of the Holocaust" opened to widespread condemnation. The conference, called for by and held at the behest of Ahmadinejad, was widely described as a "Holocaust denial conference" or a "meeting of Holocaust deniers", though Iran denied it was a Holocaust denial conference. A few months before it opened, the Iranian Foreign Ministry spokesman Hamid Reza Asefi stated: "The Holocaust is not a sacred issue that one can't touch. I have visited the Nazi camps in Eastern Europe. I think it is exaggerated." In 2013, in an interview with CNN, newly elected Iranian President Hassan Rouhani was quoted as condemning the Holocaust, stating, "I can tell you that any crime that happens in history against humanity, including the crime the Nazis created towards the Jews as well as non-Jews is reprehensible and condemnable. Whatever criminality they committed against the Jews, we condemn." Iranian media later accused CNN of fabricating Rouhani’s comments. In his official 2013 Nowruz address, Supreme Leader of Iran Grand Ayatollah Ali Khamenei questioned the veracity of the Holocaust, remarking that "The Holocaust is an event whose reality is uncertain and if it has happened, it’s uncertain how it has happened.” This was consistent with Khamenei's previous comments regarding the holocaust. In 2015, the House of Cartoon and the Sarcheshmeh Cultural Complex in Iran organized the International Holocaust Cartoon Competition, a competition in which artists were encouraged to submit cartoons on the theme of Holocaust denial. The winner of the contest will receive $12,000. Hamshahri, a popular Iranian newspaper, held a similar contest in 2006. Propaganda in the media: According to James Najarian, Holocaust deniers working for the Institute for Historical Review are not trained in history and "put out sham scholarly articles in the mock-academic publication, the Journal of Historical Review". They appeal to "our objectivity, our sense of fair play, and our distrust of figurative language". Thus, they rely on facts to grab the readers' attention. These facts, however, are strung by what Najarian calls "fabricated decorum" and are re-interpreted for their use. For example, they pay particular attention to inconsistencies in numbers. Holocaust denial propaganda in all forms has been shown to influence the audiences that it reaches. In fact, even the well-educated—that is, college graduates and current university students alike—are susceptible to such propaganda when it is presented before them. This stems from the growing disbelief that audiences feel after being exposed to such information, especially since Holocaust witnesses themselves are decreasing in number. Studies centered on the psychological effects of Holocaust denial propaganda confirm this assertion. Linda M. Yelland and William F. Stone, in particular, show that Denial essays decrease readers' belief in the Holocaust, regardless of their prior Holocaust awareness. Reactions to Holocaust denial- Types of reaction: Scholarly response to Holocaust denial can be roughly divided into three categories: Some academics refuse to engage Holocaust deniers or their arguments at all, on grounds that doing so lends them unwarranted legitimacy. A second group of scholars, typified by the American historian Deborah Lipstadt, have tried to raise awareness of the methods and motivations of Holocaust denial without legitimizing the deniers themselves. "We need not waste time or effort answering the deniers' contentions," Lipstadt wrote. "It would be never-ending.... Their commitment is to an ideology and their 'findings' are shaped to support it." A third group, typified by the Nizkor Project, responds to arguments and claims made by Holocaust denial groups by pointing out inaccuracies and errors in their evidence. Even scholarly responses, however, can trigger vigorous rebuttals. In 1996, the British historian David Irving brought a civil defamation suit against Lipstadt and her publisher, stemming from Lipstadt's book Denying the Holocaust, in which she named Irving as "one of the more dangerous" Holocaust deniers, because he was a published author, and was viewed by some as a legitimate military historian. He was "familiar with historical evidence", she wrote, and "bends it until it conforms with his ideological leanings and political agenda". Irving, who appeared as a defense witness in Ernst Zündel's trial in Canada, and once declared at a rally of Holocaust deniers that "more women died in the back seat of Edward Kennedy's car than ever died in a gas chamber at Auschwitz," claimed that Lipstadt's allegation damaged his reputation. After a two-month trial in London, the trial judge issued a 333-page ruling against Irving. In December 1991 the American Historical Association issued the following statement: The American Historical Association Council strongly deplores the publicly reported attempts to deny the fact of the Holocaust. No serious historian questions that the Holocaust took place. This followed a strong reaction by many of its members and commentary in the press against a near-unanimous decision that the AHA had made in May 1991 that studying the significance of the Holocaust should be encouraged. The association's May 1991 statement was in response to an incident where certain of its members had questioned the reality of the Holocaust. The December 1991 declaration is a reversal of the AHA's earlier stance that the association should not set a precedent by certifying historical facts. Public figures and scholars: A number of public figures and scholars have spoken out against Holocaust denial, with some – such as literary theorist Jean Baudrillard – likening Holocaust denial to "part of the extermination itself". The American Historical Association, the oldest and largest society of historians and teachers of history in the United States, states that Holocaust denial is "at best, a form of academic fraud". In 2006, UN Secretary General Kofi Annan said: "Remembering is a necessary rebuke to those who say the Holocaust never happened or has been exaggerated. Holocaust denial is the work of bigots; we must reject their false claims whenever, wherever and by whomever they are made." Holocaust survivor and Nobel Prize winner Elie Wiesel calls the Holocaust "the most documented tragedy in recorded history. Never before has a tragedy elicited so much witness from the killers, from the victims and even from the bystanders—millions of pieces here in the museum what you have, all other museums, archives in the thousands, in the millions." He made a similar statement on a special edition of The Oprah Winfrey Show after his final trip to Auschwitz, along with host Winfrey. In January 2007, the United Nations General Assembly condemned "without reservation any denial of the Holocaust", though Iran disassociated itself from the resolution. In July 2013, Iran's then president-elect Hassan Rohani described Ahmadinejad's remarks about the Holocaust and Israel as "hate rhetoric" and in September 2013 Rohani stated that "The Nazis carried out a massacre that cannot be denied, especially against the Jewish people" and "The massacre by the Nazis was condemnable. We never want to sit by side with the Nazis..They committed a crime against Jews — which is a crime against..all of humanity." While declining to give a specific number of Jewish victims, Iranian analysts suggested that "Rouhani pushed the envelope as far as it could go..without infuriating the supreme leader, Ayatollah Ali Khamenei, and other conservatives back home." Former SS members: Critics of Holocaust denial also include members of the Auschwitz SS. Camp physician and SS-Untersturmführer Hans Münch considered the facts of Auschwitz "so firmly determined that one cannot have any doubt at all", and described those who negate what happened at the camp as "malevolent" people who have "personal interest to want to bury in silence things that cannot be buried in silence". Zyklon B handler and SS-Oberscharführer Josef Klehr has said that anyone who maintains that nobody was gassed at Auschwitz must be "crazy or in the wrong". SS-Unterscharführer Oswald Kaduk has stated that he does not consider those who maintain such a thing as normal people. Hearing about Holocaust denial compelled former SS-Rottenführer Oskar Gröning to publicly speak about what he witnessed at Auschwitz, and denounce Holocaust deniers, stating: I would like you to believe me. I saw the gas chambers. I saw the crematoria. I saw the open fires. I was on the ramp when the selections took place. I would like you to believe that these atrocities happened because I was there. Holocaust denial and antisemitism: Holocaust denial is widely known to be antisemitic. The Encyclopedia of Genocide and Crimes Against Humanity, for example, defines Holocaust denial as "a new form of anti-Semitism, but one that hinges on age-old motifs". The Anti-Defamation League has stated that "Holocaust denial is a contemporary form of the classic anti-Semitic doctrine of the evil, manipulative and threatening world Jewish conspiracy" and French historian Valérie Igounet has written that "Holocaust denial is a convenient polemical substitute for anti-semitism." In 2005, the European Monitoring Centre on Racism and Xenophobia (now the Fundamental Rights Agency) published a "working definition" of antisemitism which gave as an example of the way that antisemitism might manifest itself, "denying the fact, scope, mechanisms (e.g., gas chambers) or intentionality of the genocide of the Jewish people at the hands of National Socialist Germany and its supporters and accomplices during World War II (the Holocaust)". Some have argued that not all Holocaust deniers are necessarily antisemitic. In a defense of Holocaust denier Bishop Richard Williamson against the charge of being antisemitic, the journalist and writer Kevin Myers argued "It is not anti-Semitic to make a fool of yourself in public about a historical fact. It is anti-Semitic to preach or promote a dislike of Jews because they are Jews, which is what Bishop Williamson has not done." According to Walter Reich, psychiatrist and then senior scholar at the Woodrow Wilson International Center for Scholars, one-time director of the United States Holocaust Memorial Museum, and now professor of international affairs at George Washington University: The primary motivation for most deniers is anti-Semitism, and for them the Holocaust is an infuriatingly inconvenient fact of history. After all, the Holocaust has generally been recognized as one of the most terrible crimes that ever took place, and surely the very emblem of evil in the modern age. If that crime was a direct result of anti-Semitism taken to its logical end, then anti-Semitism itself, even when expressed in private conversation, is inevitably discredited among most people. What better way to rehabilitate anti-Semitism, make anti-Semitic arguments seem once again respectable in civilized discourse and even make it acceptable for governments to pursue anti-Semitic policies than by convincing the world that the great crime for which anti-Semitism was blamed simply never happened—indeed, that it was nothing more than a frame-up invented by the Jews, and propagated by them through their control of the media? What better way, in short, to make the world safe again for anti-Semitism than by denying the Holocaust? The French historian Pierre Vidal-Naquet described the motivation of deniers more succinctly: One revives the dead in order the better to strike the living. Examination of claims: The key claims which cause Holocaust denial to differ from established fact are: -The Nazis had no official policy or intention of exterminating Jews. -Nazis did not use gas chambers to mass murder Jews. -The figure of 5 to 6 million Jewish deaths is a gross exaggeration, and the actual number is an order of magnitude lower. Other claims include the following: -Stories of the Holocaust were a myth initially created by the Allies of World War II to demonize Germans, Jews having spread this myth as part of a grander plot intended to enable the creation of a Jewish homeland in Palestine, and now to garner continuing support for the state of Israel. -Documentary evidence of the Holocaust, from photographs to The Diary of Anne Frank, is fabricated. -Survivor testimonies are filled with errors and inconsistencies, and are thus unreliable. -Interrogators obtained Nazi prisoners' confessions of war crimes through the use of torture. -The Nazi treatment of Jews was no different from what the Allies did to their enemies in World War II. Holocaust denial is widely viewed as failing to adhere to principles for the treatment of evidence that mainstream historians (as well as scholars in other fields) regard as basic to rational inquiry. The Holocaust was well documented by the bureaucracy of the Nazi government itself. It was further witnessed by the Allied forces who entered Germany and its associated Axis states towards the end of World War II. It was also witnessed from the inside by non-Jewish captives such as Catholic French Resistance member André Rogerie who wrote extensively and testified about his experiences in seven camps including Auschwitz-Birkenau and also produced the oldest contemporary sketch of a camp crematorium. According to researchers Michael Shermer and Alex Grobman, there is a "convergence of evidence" that proves that the Holocaust happened. This evidence includes: -Written documents—hundreds of thousands of letters, memos, blueprints, orders, bills, speeches, articles, memoirs, and confessions. -Eyewitness testimony—accounts from survivors, Jewish Sonderkommandos (who helped load bodies from the gas chambers into the crematoria in exchange for a chance of survival), SS guards, commandants, local townspeople, and even high-ranking Nazis who spoke openly about the mass murder of the Jews. -Photographs—including official military and press photographs, civilian photographs, secret photographs taken by survivors, aerial photographs, German and Allied film footage, and unofficial photographs taken by the German military. -The camps themselves—concentration camps, work camps, and extermination camps that still exist in varying degrees of originality and reconstruction. -Inferential evidence or argument from silence — population demographics, reconstructed from the pre–World War II era; if six million Jews were not killed, what happened to them? Much of the controversy surrounding the claims of Holocaust deniers centers on the methods used to present arguments that the Holocaust allegedly never happened as commonly accepted. Numerous accounts have been given by Holocaust deniers (including evidence presented in court cases) of claimed facts and evidence; however, independent research has shown these claims to be based upon flawed research, biased statements, or even deliberately falsified evidence. Opponents of Holocaust denial have documented numerous instances in which such evidence was altered or manufactured (see Nizkor Project and David Irving). According to Pierre Vidal-Naquet, "in our society of image and spectacle, extermination on paper leads to extermination in reality." Laws against Holocaust denial: Holocaust denial is explicitly or implicitly illegal in 16 countries: Austria, Belgium, Czech Republic, France, Germany, Hungary, Israel, Liechtenstein, Lithuania, Luxembourg, Netherlands, Poland, Portugal, Romania, Slovakia, and Switzerland. Romania officially denied the Holocaust occurred on its territory up until the Wiesel Commission in 2004. The European Union's Framework decision on Racism and Xenophobia states that denying or grossly trivializing "crimes of genocide" should be made "punishable in all EU Member States". Slovakia criminalized denial of fascist crimes in general in late 2001; in May 2005, the term "Holocaust" was explicitly adopted by the penal code and in 2009, it became illegal to deny any act regarded by an international criminal court as genocide. In 2010 the Parliament of Hungary adopted legislation punishing the denial of the genocides committed by National Socialist or Communist systems, without mentioning the word "Holocaust". Such legislation remains controversial. In October 2007, a tribunal declared Spain's Holocaust denial law unconstitutional. In 2007 Italy rejected a denial law proposing a prison sentence of up to four years. In 2006 the Netherlands rejected a draft law proposing a maximum sentence of one year on denial of genocidal acts in general, although specifically denying the Holocaust remains a criminal offense there. The United Kingdom has twice rejected Holocaust denial laws. Denmark and Sweden have also rejected such legislation. A number of deniers have been prosecuted under various countries' denial laws. French literature professor Robert Faurisson, for example, was convicted and punished under the Gayssot Act in 1990. Some historians oppose such laws, among them Pierre Vidal-Naquet, an outspoken critic of Faurisson, on the grounds that denial legislation imposes "historical truth as legal truth". Other academics favor criminalization. Holocaust denial, they contend, is "the worst form of racism and its most respectable version because it pretends to be a research". Focus on Allied war crimes in Holocaust denial literature: The focus on supposed Allied atrocities during the war has also been a theme in Holocaust denial literature, particularly in countries where outright denial of the Holocaust is illegal. According to historian Deborah Lipstadt, the concept of "comparable Allied wrongs", such as the expulsion of Germans after World War II and the bombing of Dresden, is at the center of, and a continuously repeated theme of, contemporary Holocaust denial; phenomenon she calls "immoral equivalencies". Pierre Vidal-Naquet pointed out the same phenomenon in the earlier version of Les Assassins de la mémoire under the title Auschwitz et le tiers monde (Les Assassins de la mémoire, Paris, 2005, pp. 170–180), and accurately about the declarations of Klaus Barbie's lawyer Jacques Vergès. In 1977, Martin Broszat, in a review of David Irving's book Hitler's War, maintained that the picture of World War II drawn by Irving was done in a such way to imply moral equivalence between the actions of the Axis and Allied states with both sides equally guilty of terrible crimes, leading to Hitler's "fanatical, destructive will to annihilate" being downgraded to being "no longer an exceptional phenomenon". Other genocide denials: Other acts of genocide have met similar attempts to deny and minimize. Gregory H. Stanton, formerly of the US State Department and the founder of Genocide Watch, lists denial as the final stage of a genocide development: "Denial is the eighth stage that always follows a genocide. It is among the surest indicators of further genocidal massacres. The perpetrators of genocide dig up the mass graves, burn the bodies, try to cover up the evidence and intimidate the witnesses. They deny that they committed any crimes, and often blame what happened on the victims."