Introduction

“Congress shall make no law respecting an establishment of religion, or prohibiting the free exercise thereof; or abridging the freedom of speech, or of the press; or the right of the people peaceably to assemble, and to petition the Government for a redress of grievances.”[1]

Freedom of speech is a fundamental aspect of American society and an important classical liberal ideal, but it is a right which is not always convenient, convivial, or comity-inducing. In fact, allowing the full flourishing of the freedom of expression and speech often includes permitting speech that much of society will find despicable, evil, offensive, or harmful. Unfortunately, there is a strong cultural – and outside of the United States, legal – movement to restrict speech freedoms and police the public discourse, sometimes with actual police officers.[2] This trend is only accelerating with the mass adoption of social media and Internet communications more broadly, as well as the perpetually searchable online past of nearly everyone in society. So-called ‘cancel culture’ is commonplace in certain circles of political and social activism, and virtually every potentially controversial opinion (and many that are not) is met with the metaphorical gnashing of teeth and rending of garments.[3] There are increasing levels of pushback against this trend, but the idea of ‘de-platforming’, stifling, or censoring speech which the vast majority of society considers beyond the pale – support for terrorism and blatant white supremacy, to give two examples – is quite popular, especially among younger people. According to a poll conducted by the Campaign for Free Speech, “61 percent of Americans agree that free speech should be restricted, and 51 percent believe that the First Amendment, ratified in 1791, should be rewritten to reflect the new cultural norms of today. Millennials feel a greater sense of negativity from free speech, with 57 percent agreeing that the First Amendment should be rewritten, and 54 percent believing that possible jail time would be an appropriate consequence for ‘hate speech.’”[4] Despite the strong American constitutional protections for free speech, as seen in the First Amendment quoted above, without a strong cultural presumption and acceptance of the values around free speech, the right itself can be chipped away.

The concept of speech freedom in the modern West sprung from the age of the Enlightenment, where the notion of liberalism and tolerance of divergent viewpoints and ideas was espoused by the leading philosophical lights of the day. One such famous philosophe was the Frenchman Francois-Marie Arouet – better known by his pen name, Voltaire – who famously (and possibly apocryphally) stated that “I may disagree with you, but I defend to the death your right to say it.”[5] This attitude was truly revolutionary for the time when he lived, the eighteenth century, but it had become far more widely accepted during the liberal revolutions of the nineteenth century and into the twentieth. Exceptions to this rule have generally been allowed by law, but have been curtailed in most instances in the United States to allow as much speech as possible as long as it does not cause direct, obvious, immediate harm to those not speaking. Perhaps the most eloquent, learned, and principled declaration in support of a nigh-unfettered right to speech freedom was espoused by the late US Supreme Court Justice Louis Brandeis in his concurrence in the Whitney v. California case in 1927. The entire opinion is well-worth reading, as it lays out a clear, historically and ideologically grounded defense of the right to free expression; still, one particular passage from the concurrence has stood the test of time and emerged as the go-to vindication of the First Amendment for free speech absolutists and defenders [emphasis added]:

Those who won our independence by revolution were not cowards. They did not fear political change. They did not exalt order at the cost of liberty. To courageous, self-reliant men, with confidence in the power of free and fearless reasoning applied through the processes of popular government, no danger flowing from speech can be deemed clear and present, unless the incidence of the evil apprehended is so imminent that it may befall before there is opportunity for full discussion. If there be time to expose through discussion the falsehood and fallacies, to avert the evil by the processes of education, the remedy to be applied is more speech, not enforced silence. Only an emergency can justify repression. Such must be the rule if authority is to be reconciled with freedom.[6]

The words of Justice Brandeis are strong and justified, yet they are gaining less purchase in the twenty-first century than they had in much of post-war American – and Western – history. As stated above, many Americans find the concept of free speech outdated and prioritize other concerns, like the comfort of marginalized groups, over the constitutional right to speech freedom; this is especially true among younger Americans, who are more bearish on the First Amendment than are their elders.[7] One issue within the realm of speech suppression that has gained wide acceptance in the United States and abroad – particularly in Europe – has been the question of Holocaust denial.

Recently, efforts have been made across social media to tamp down and censor posts which advocate for Holocaust denial or distortion, as well as ban those accounts which promote these lies.[8] Social media and other private companies are not government actors and therefore are not impacted by the First Amendment protections against speech suppression, but the trend of censoring Holocaust denial has not been limited to private actors. Over the course of the late twentieth century, laws were passed by a wide variety of European states, as well as Canada, to criminalize Holocaust denial or promotion of Nazi or neo-Nazi ideas; currently there are at least thirteen nations in Europe – including major ones like France, Germany, and Poland – which have criminal penalties on the books for this specific form of speech.[9] Several Holocaust deniers, including David Irving and Ernst Zündel – more on whom later – have been charged and convicted under these statutes, which can hand down fines, jail terms, and permanent bans from entering the country in the future. It is good that governments and private actors are standing against the perfidy of Holocaust denial, but do these sorts of actions – ones which essentially seek to eliminate any trace of Holocaust denial – work?

As is clear through survey data, the answer is not a compelling endorsement of the censorship approach. As per a 2018 study published by the Conference on Jewish Material Claims Against Germany, a Holocaust remembrance and Jewish advocacy organization, “Nearly one-third of all Americans…believe that substantially less than 6 million Jews were killed (two million or fewer) during the Holocaust,” as well as finding that “almost half of Americans (45 percent) cannot name a single” concentration camp or ghetto.[10] The same organization carried out a similar survey in 2020, focusing especially on younger generations of Americans – Millennials and Gen Z – and their findings were even more concerning for those who seek to promote Holocaust education and discredit denialism. In that survey, sixty-three percent of respondents did not know that six million Jews were killed in the Holocaust and thirty-six percent of those surveyed believed that fewer than two million Jews were killed; forty-eight percent of surveyed Millennials and Gen Z could not name a single ghetto or concentration camp and a staggering fifty-six percent were unable to identify the most infamous death camp – Auschwitz-Birkenau.[11] The results were even more concerning with respect to the prevalence of Holocaust denial and victim blaming. A full eleven percent of respondents believed that the Jews themselves caused the Holocaust – a finding that goes up to nineteen percent in New York, the US state with the largest Jewish population[12] – and nearly half of those surveyed stated that they have witnessed examples of Holocaust denial or distortion on social media or the Internet more broadly.[13] If these figures are even remotely accurate, the censorship approach has failed spectacularly.

Given the widespread lack of knowledge of the Holocaust among all generations of Americans, combined with the ease of modern communications and information dissemination, it is not surprising that the lies of Holocaust deniers have seen increasing purchase. It is essentially impossible to entirely shut down speech in the Internet age, as the means of dissemination and transmission are myriad and constantly evolving; oftentimes the aggressive speech policing regimes can have an opposite impact, making it more likely for people who are intrigued to search out the so-called ‘real facts’ on the Holocaust. Much like the failure of the ‘Just Say No’ anti-drug campaign[14], simply trying to eliminate all Holocaust denial propaganda from the vastness of the Internet is unrealistic and may have deleterious effects by unintentionally promoting this ‘secret knowledge’. In this vein, it is critical that historians, advocacy organizations, and scholars take the sage wisdom of Justice Brandeis to heart and fully embrace his remedy for malign speech: more speech. Historians in particular should not seek to shut down debate or good-faith questions for the sake of denying the denialists their quarry; instead, those in the position of expertise or knowledge must directly confront these scurrilous lies and debunk them for the express purpose of education. Those figures referenced in the studies earlier do not only show a lack of Holocaust awareness and the prevalence of misinformation, they also show a genuine desire to learn the truth and understand what actually happened to the Jews of Europe in the Second World War; the 2018 study shows that more than ninety percent of respondents thought that Holocaust education should be mandated[15], while the more recent study of American youths found that eighty percent believed that Holocaust education should continue so as to prevent future atrocities.[16] This willingness to learn should be fully embraced by historians and Holocaust educators, who must work to present and debunk false information about the Holocaust just as much as they teach the truth. In the twenty-first century, misinformation can spread like wildfire, even if it is purportedly censored; it is imperative on historians to not allow this information to go unchallenged in the public square. As a part of that effort, this paper seeks to apply the remedy advocated by Justice Brandeis – the first Jewish member of the Supreme Court – that is, more speech, and debunk the falsehoods of Holocaust denial.

Part I: Holocaust Deniers and Their Claims

What is Holocaust Denial?

Before delving into the specifics of Holocaust denial and those who espouse it, it is necessary to define the term itself. What is Holocaust denial? How can one tell a denialist versus someone who lacks knowledge and is curious? Does asking questions about the historical event that was the Holocaust make one a denier? These questions all have answers, but the distinction between Holocaust denial and someone who is ‘just asking questions’ is often blurry and can be contentious; experts on the phenomenon commonly disagree around the edges and there is no universally-accepted answer. Still, there are some broad definitional strokes that can be agreed upon. The most basic definition is the one espoused by the United States Holocaust Memorial Museum, which says that “Holocaust denial is any attempt to negate the established facts of the Nazi genocide of European Jews. Holocaust denial and distortion are forms of antisemitism, prejudice against or hatred of Jews. Holocaust denial and distortion generally claim that the Holocaust was invented or exaggerated by Jews as part of a plot to advance Jewish interests.”[17] This definition has multiple aspects, each of which deserve explication. First, the definition rests on a foundation of negation; that is, Holocaust deniers explicitly seek to overturn the basic historical facts of the Holocaust. This can become a bit tricky when discussing edge cases, as legitimate historical revision of the Holocaust has happened, especially with respect to early claims which have been reviewed and altered to better match the facts of the situation. Despite these edge cases, the foundation is strong, as Holocaust deniers seek generally to undercut and reverse the factual historical information about the genocide. Next, the passage mentions how Holocaust denial is itself a form of anti-Semitism, a charge which is undoubtedly true and an aspect of denial which separates hardcore denialists from those who are searching for real information. As we will see, explicit anti-Semitic rhetoric is commonplace in the works and writings of deniers. Finally, the last aspect of this initial definition that warrants comment is the assertion that deniers claim that the ‘Holocaust hoax’ was invented by Jews as a means to consolidate and expand their global power; this is a critical aspect of what marks out someone as a denier – anti-Semitic conspiratorial thinking and exaggeration of the power of the Jews.

Another useful basic definition comes from the writer Robert Solomon Wistrich, who states that “Holocaust denial is a postwar phenomenon at whose core lies the rejection of the historical fact that six million Jews were murdered by the Nazis during World War II. Alongside explicit repudiation of the Holocaust, denial includes the minimization, banalization, and relativization of the relevant facts and events, so as to cast doubt on the uniqueness or authenticity of what happened during the Shoah.”[18] Wistrich’s definition touches on many of the same factors as that of the US Holocaust Memorial Museum, but mentions some other features which also tend to characterize Holocaust denialism. One such assertion is that deniers focus on disputing and discrediting the widely-accepted Jewish death toll from the Holocaust of six million dead; the second part of this paper will specifically address the established death toll and debunk the false narratives with which deniers attack it. Many of the seminal works of Holocaust denial reference this impossibly-high, yet totally factual, figure, calling it into question with titles like ‘The Myth of the Six Million’, ‘The Six Million Swindle’, and ‘Did Six Million Really Die?’ As the Holocaust death toll is one of the most commonly referenced facts about the genocide, it is a prime target for those who wish to deny its legitimacy. The second sentence of Wistrich’s definition is just as important in understanding the tactics and rhetorical strategies of Holocaust deniers; they routinely use moral and historical relativism to diminish the uniqueness of the Holocaust as an historical atrocity. When reading the works of deniers, this is a trope which rears its ugly head quite frequently, especially when trying to blame the Jews for their own mass murder and minimize the Holocaust by unfairly comparing it to other instances of brutality. The issue of comparative study of the Holocaust is a thorny one, as scholars fall on both sides of the divide – some are for comparison as a means of understanding genocide, while others say that any comparison of the Holocaust to other genocidal events can only diminish it. This is far too broad an issue to explore in depth here, but suffice it to say that the Holocaust comparisons made by deniers are always in bad faith and tend to excuse the actions of the Nazi government through the comparative process, using other atrocities for cover.

The final definition that helps to fill out an understanding of Holocaust denial as an ideology and phenomenon comes from the scholars Michael Shermer and Alex Grobman, in their book Denying History. They touch on many of the same definitional aspects as the previous two sources, but they also explain a bit more about the common claims of deniers which mark them out as such, as well as the difference between legitimate historical revisionism and the denial of history itself.[19] The first assertion made by these authors which is worth detailing is their conception of three major definitional pillars of the Holocaust, attacks on which mark out Holocaust deniers: “the killing of six million, gas chambers, and intentionality.”[20] Each of these pillars has seen real historical revision work – gas chambers were initially thought to exist at far more camps than they did, death tolls have been updated, and there is legitimate debate over the degree of intentionality in the Final Solution – but the denialist community tends to attack them from a position of attempting to completely reverse the historical truth of the Holocaust versus trying to gain a more nuanced and detailed picture of the established history. Shermer and Grobman also mention the denialist trope that the Holocaust is untouchable and forever in stasis, stating that “Holocaust deniers claim that there is a force field of dogma around the Holocaust – set up and run by the Jews themselves – shielding it from any change.”[21] This assertion by deniers is completely untrue, as there has been significant refinement of the facts surrounding the Holocaust, something the deniers themselves know, but that the broader public is often unaware of.[22] One instance of this true revision comes from the idea that Jewish corpses were used on a mass scale to produce soap, which was then sold to German citizens and others; there is no evidence that this process was ever undertaken on a mass scale, although the evidence is mixed as to whether it may have happened in isolated incidents.[23] Deniers take this legitimate revision and apply it to every aspect of the Holocaust in an attempt to undercut the historical fact of the genocide, a clear distortion of the actual historical revision process and another marker of Holocaust denialism.

The aforementioned three definitions cover much of what can be considered Holocaust denial, as well as what can be seen as legitimate historical revision. There are a few major components of denialism which are commonplace and separate the Holocaust denier from someone who may not be fully in that group – or is working in good faith to provide better information about the genocide of the European Jews. Those factors include anti-Semitic references to Jews or exaggeration of the power of the global Jewish community, conspiratorial thinking surrounding the Holocaust and Jews, outright refusal to engage with factual information or critical readings of their own work, contempt for Israel and Zionism, moral and historical relativism, deliberate misinterpretations of legitimate historical evidence and revision, and a bad faith approach meant to erase the Holocaust from the historical record. There are more denialist tropes which pop up in their works, but these are fairly common and serve to distinguish real denialism from simple naïveté. Now that we have some definitions relating to Holocaust denial, another question presents itself: who are the Holocaust deniers?

Who Denies the Holocaust?

As with its ‘cousins’ anti-Semitism and anti-Zionism, Holocaust denial is an ideology unfettered by geographic, political, or temporal bounds. People on both ends of the political spectrum and around the world deny the Holocaust, often finding themselves on the ‘same side’ as people who they would otherwise despise. For one such example of these uncomfortable alliances, see Figure V in Appendix B, which reproduces an annotation in one of the sources for this piece; in that annotation, the writer – a clear denier – complains that one of their fellow travelers is a Muslim living in Sweden, somewhere the annotator asserts that “only whites should live.”[24] This is just one example of the expansive nature of Holocaust denialism, which connects radical Islamists to European neo-Nazis to left-wing anti-Semites. The political scope of Holocaust denial is an oft-overlooked aspect of the phenomenon; the denial movement is frequently associated only with far-right-wing politics, particularly of the fascist or neo-Nazi variety[25], but there are also Holocaust deniers on the political far-left. These leftist denialists are typically associated with a virulent form of anti-Zionism and can come from socialist, communist, and black nationalist approaches.[26] They generally advocate for the false notion that Zionists knew about and supported the Holocaust as a means to gain their own state, which was formed as Israel in 1948; in an explicit endorsement of this crackpot theory, the “self-described Pan-African revolutionary” Kwame Ture (formerly known as Stokely Carmichael) stated in a 1990 speech that “…the Zionists joined with the Nazis in murdering Jews, so they would flee to Palestine.”[27] This theory – a nexus of anti-Semitism, anti-Zionism, and Holocaust denial – has been widely adopted by a burgeoning denialist community in the Arab world; the ideology has found footing in the Palestinian liberation movement[28], was supported by the late Iraqi dictator Saddam Hussein[29], and is considered state policy in Iran – a nation that hosted a conference of Holocaust deniers in 2006.[30] This Arab dalliance with Nazism has a long history going back even prior to the Second World War, where “an alliance based on shared antagonism toward Britain and toward Zionism, as well as on shared anti-Semitic ideology, had been emerging between the Nazis and the Grand Mufti of Jerusalem, Amin al-Husseini, since 1937.”[31]  Besides the places more usually associated with Holocaust denial – particularly the United States and Western Europe – denialism has also taken root in Canada[32] and in Eastern Europe[33], the site of many of the Holocaust’s worst atrocities. There are growing communities of Holocaust denialists in nations including Romania, Poland, Slovakia, and Hungary, as many in those nations seek to rehabilitate their wartime leaders who both fought Communism and participated in the Holocaust.[34] Denialism clearly has broad reach politically and geographically, but its evolution over time – its temporal reach – is just as important.

Denialism in earnest began almost immediately after the end of the Second World War, but its foundations lay in earlier, more legitimate scholarship which found American participation in the First World War to have been morally and politically wrong.[35] Deniers in the modern day seek to compare themselves favorably with these historians, but their efforts at diminishing and denying the Holocaust are pseudoscience compared to the actual historiographical approach – agree with it or not – of the post-World War I revisionist historians.[36] In terms of true Holocaust denial, it came onto the intellectual scene earliest in France, with men of divergent political leanings like the fascist Maurice Bardèche and the socialist Paul Rassinier – a former prisoner of the Nazis who was interned at Buchenwald – writing books and pamphlets which denied the reality of the Jewish genocide.[37] Rassinier in particular would become quite influential in the denial movement, publishing a compendium of his denialist works in English under the title Debunking the Genocide Myth in 1978[38]; his path from his early writings on the Holocaust to their 1978 culmination is fascinating, as it shows in microcosm the evolution of the denial movement as a whole. In Rassinier’s first Holocaust-related works, he focused primarily on questioning survivor testimony and blaming the horrible conditions of the concentration camps – and the attendant death that came along with them – on the prisoners themselves.[39] In his later works, which influenced the development of Holocaust denial more generally, Rassinier sought to deny the reality of the Holocaust altogether, specifically focusing on ‘proving’ that the accepted death toll of six million was a deliberate falsehood conspiratorially concocted by world Jewry – he called this the ‘genocide myth’.[40] That second approach is what truly stuck and is commonly seen as the main thrust of Holocaust denial today; any further evolution in the movement after the late 1970s was in tone, rhetoric, and style more than it was in concept and content.

Over time, Holocaust deniers sought to take on the veneer of legitimacy, including through the establishment of the Institute for Historical Review (IHR) in 1978 by the anti-Semitic propagandist and extremist Willis A. Carto.[41] This organization uses historiographical language and presentation to promote itself as a legitimate organization dedicated to the revision of history – publishing a pseudo-academic journal and holding near-annual conferences – yet it focuses almost exclusively on Holocaust denial and other anti-Semitic topics.[42] The Institute, through its publishing arm Noontide Press, has distributed many of the more influential and widely-read Holocaust denial tracts, including Rassinier’s books and the pamphlet “Did Six Million Really Die?”; the Anti-Defamation League lists a representative sample in an appendix to Hitler’s Apologists.[43] There are also Holocaust deniers with reasonable levels of actual historical knowledge and academic titles which one may find convincing at first glance. Mark Weber, an editor at the IHR[44] and the co-founder of a denialist organization called the Committee for Open Debate on the Holocaust (CODOH)[45], has a master’s degree in Modern European History from Indiana University.[46] David Irving, a prolific author of books on the Second World War which often excuse the actions of the Nazis and Adolf Hitler, has serious experience in historical research and translation – he was contracted to translate the purported diaries of Joseph Goebbels by the British paper the Sunday Times – and has occasionally written a work which is factual although biased against the Allies.[47] Many consider him to be “arguably the most historically sophisticated of the deniers,”[48] and he is seen by some historians “as a first-rate archivist” despite his selective use of archival material to fit his pro-Reich narrative.[49] Arthur Butz, a PhD and former professor of electrical engineering at Northwestern University, is one of the best examples of the denialist trend towards groping towards academic respectability; his book, The Hoax of the Twentieth Century, is presented as an academic treatise replete with footnote citations and a full bibliography.[50] This veneer of academic rigor, as well as Butz’s criticisms of earlier denialist works for their blatant falsehoods, camouflages the same anti-Semitism and contempt for the historical fact of the Holocaust that characterized those earlier works.[51] These attempts at gaining academic legitimacy for their anti-Semitic and anti-Zionist messages show how the denialist movement has evolved to put forward a more ‘palatable’ image of Holocaust denial. Although the form has changed, the substance has remained as noxious as ever.

How Do They Deny the Holocaust?

Holocaust deniers utilize a wide variety of rhetorical tactics and stratagems to forward their factually inaccurate assertions about the reality of the genocide of the European Jews. There are five major tactics which comprise the ‘playbook’ of Holocaust denial; nearly every work written by denialists contains at least one – usually more – of these strategies. First, deniers widely ignore contradictory evidence and massage statistics to prove their points. This can be seen most readily in the ways that deniers seek to ‘debunk’ the accepted Holocaust death toll of six million Jews; they miscalculate population figures, they ignore evidence of mass murder and focus instead on phantom emigration, and they even refuse to accept documentation created by the Nazis which disprove the denialist hypothesis. Holocaust deniers seem to have an uncanny ability to ignore opposing evidence; they see direct testimony of Jewish survivors as entirely fictional, consider nearly all documents relating to the Holocaust to be forgeries or manipulations – unless they are written in coded language that prima facie seems to acquit the Nazis – and see all post-war Nazi testimony as fatally flawed by dint of being obtained under duress or coercion.[52] Next, deniers tend to omit important historical context or data, as well as reading their own biased conclusions into the data they do accept. One such example appears in the denialist pamphlet “Did Six Million Really Die?” by Richard Verrall, a British neofascist writing under the pen name Richard Harwood.[53] In that pamphlet, Verrall claims that, with respect to the Jews of Hungary, mass emigration through 1944 must have ensured that there were “very low” numbers of Hungarian Jewish casualties given that the war ended in 1945[54]; he entirely omits the fact that mass deportations of Hungarian Jews did not begin until May 1944, resulting in over five-hundred-fifty-thousand deaths in a span of just a few months.[55]

Third, Holocaust deniers tend to cherry-pick sources which support their assertions as well as ones on the ‘other side’ which are easy rhetorical strawmen to defeat. One thing that is incredibly commonplace in the literature of Holocaust denial is the incestuous cross-citation of other deniers. Pamphlets like Verrall’s cite ‘research’ from earlier deniers like Rassinier and the American Harry Elmer Barnes to prove their assertions, something which can seem legitimate if one does not track the information to its denialist source. By citing one another, Holocaust deniers create a self-reinforcing community which can lend the air of expertise to deniers who can claim they are widely cited – without, of course, the acknowledgement that they are only widely cited within their own small group. Deniers also choose easily debunked narratives – ones which often have been debunked by actual historians – to prove that the entirety of the Holocaust is a fabrication. One such example is the story of the Jewish soap which was related earlier; this is a story which is referenced in many denialist works as proof that the testimony of Jewish survivors is falsified. Another instance of this cherry-picking of exaggerated claims comes with respect to the initial death toll claimed by the USSR at Auschwitz-Birkenau: four million Jewish dead.[56] This figure was never accepted by Western scholars and was likely exaggerated by the Soviets just after the war as a means of underscoring the Nazi plague which caused mass death in Eastern Europe – a territory now behind the Iron Curtain – and presenting themselves as the liberators and saviors of Europe. The method by which the Soviets calculated this figure – extrapolating death counts from the potential capacity of the crematoria at full steam – is inherently flawed given the knowledge historians have about how the killing process worked and the stages by which the crematoria complex at Auschwitz evolved. Deniers claim that the downward revision of the incorrect four million figure proves that all death totals are exaggerated, when in fact it proves that legitimate scholars are more than willing to question and debunk false narratives surrounding the Holocaust – even ones which purportedly increase the death toll.[57]

Fourth, Holocaust deniers use moral relativism and false equivalence as a crutch to defend their arguments that the Holocaust was overblown and the mass-murder of the Jews – if it even happened – may have indeed been justified. The most commonplace example of false equivalence revolves around the myth that the Nazis were just defending Germany against a world Jewish population which sought its destruction. In his denialist tract “The Myth of the Six Million”, David Hoggan writes that “Chaim Weizmann, the Zionist leader of the Jewish agency in London, had declared war on Germany on behalf of all Jews throughout the world as early as September 5, 1939”[58]; he uses this claim to justify the Nazi internment of Jews purely as a national security matter. This assertion has been repeated throughout denialist works and has clearly sank in; Figure IV in Appendix B shows another annotation which mirrors this point exactly.[59] Finally, Holocaust deniers engage in conspiratorial thinking, particularly when it comes to the international role and power of the global Jewish community. Denialist tracts are chock-full of references to the extreme – and malign – power of the Jews over world affairs; again, this is echoed in the annotation reproduced in Figure III in Appendix B, which agrees with a typical espousal of the conspiracy of the internationalist Jew.[60] Conspiratorial rhetoric around Jews is nothing new, as it was a key aspect of the Nazi propaganda regime. In his excellent book The Jewish Enemy, historian Jeffrey Herf explores these conspiracies, ones which are eerily similar to those pushed by modern denialists:

Radical anti-Semitism rested on the belief that the Jews were a cohesive, politically active subject – that is, a group united on a global scale by racial bonds that transcended any allegiance to nation-states. In the Nazi view, this powerful and autonomous entity, international Jewry, controlled assorted stooges and accomplices who served its evil interests.[61]

These five attributes of Holocaust denial – ignoring contrary evidence and massaging statistics, omitting historical context, cherry-picking sources, using moral relativism, and conspiratorial thinking – are all present in their approach to the three pillars of the Holocaust as defined by Shermer and Grobman: “the killing of six million, gas chambers, and intentionality.”[62] In the following section, the claims of deniers surrounding the first of those pillars – the death toll of six million – will be explored and debunked; in doing so, we will see how these five strategies are used by deniers to push their falsehoods and how they can be combatted.

Part II: Debunking the Denial – The Case of the Six Million

Denialist Arguments and Their Rebuttals

Of the three major pillars of the Holocaust – gas chambers, intentionality, and the death toll – deniers seem to focus a great deal of their fire on the widely-accepted death toll of six million Jews. There are many reasons for this, but one of the most important is the human mind’s tendency towards innumeracy, especially when it comes to large numbers. Conceptualizing and fully comprehending just how many people six million is can be challenging for everyday people, as we are not conditioned to deal with numbers that large in our daily lives. Deniers take advantage of this common issue by overwhelming people with unrelated figures which are then used to undercut the truth of the Holocaust death toll; they often justify subtracting a certain number of dead from the total for one reason or another, repeat this action with similar justifications, and finally end up with a total death toll which is a small fraction of the horrifying reality. Oftentimes these methods are facially similar to those used by legitimate scholars but are manipulated so as to provide the ‘correct’ conclusion that only several hundred thousand Jews died instead of six million. Before diving into the falsified and misinterpreted statistics of the Holocaust deniers, it is worthwhile to explore the motivations they say are behind the ‘exaggerated’ death toll.

Deniers focus much of their rhetorical fire on the historians and statisticians who work with Holocaust death data, many of whom are Jewish; deniers see these professionals as Jews first and statisticians last, ascribing nefarious group motives to each individual scholar. Anti-Semitism jumps off the pages of many of the major denialist works, especially when it relates to the calculation of death figures. Austin App, a PhD and former English professor at the University of Scranton and LaSalle College[63], often references “World Jewry”[64] and “Talmudists”[65] in his pamphlet “The Six Million Swindle”; these disparaging terms are conspiratorial in nature, much like the rest of App’s writing. David Hoggan, in “The Myth of the Six Million”, specifically calls out Jewish scholars for falsifying the Holocaust, stating that “Jewish statisticians have done their best to magnify the number of Jews in the future occupied areas before September 1939, and June 1941, and to reduce almost fantastically the number that remained alive in June 1945.”[66] Paul Rassinier, in Debunking the Genocide Myth, spends over one hundred pages attempting – poorly – to debunk the statistics compiled by Raul Hilberg, the acclaimed author of one of the definitive early works on the Holocaust, The Destruction of the European Jews; in one passage he calls Hilberg dishonest before mentioning “as I continue to read his biographical note, I find that he is a collaborator in the Jewish Encyclopedia Handbooks and, in my judgment, that fact explains everything.”[67] He similarly points out that Hannah Arendt – a journalist and scholar of the Holocaust, as well as a Jew herself – “has the same intellectual outlook” as Hilberg, something which disqualifies their analysis as biased and false.[68] One notes that the prefix ‘Jewish’ is attached to anyone nominally associated with Judaism, while other personages quoted or discussed in these works rarely have a religious adjective appended to their name; this constant repetition of the fact that ‘so many’ people are Jews is meant to bring the reader’s mind into the conspiratorial anti-Semitic frame of the writers. Besides the paranoia of the deniers, their ascription of Jewishness to so many people is also meant to associate those labeled with the vast Jewish and Israeli plot that is the ‘Holocaust hoax’. This is important because it relates to the foundation of nearly all denialism of the Holocaust death toll: the incorrect claim that Israel is making billions of dollars annually by, as Austin App says, “Blackmailing the German People for Hard Marks With Fabricated Corpses.”[69]

All Holocaust deniers who try to subvert the accepted notion of the six million death toll do so by basing their claims on the supposed evil motives of the Jews of Israel. In his denialist tract, “Did Six Million Really Die?”, Richard Verrall claims that “the story of the Six Million Jews is serving a political purpose, even that it is a form of political blackmail,” as he and other deniers say that Israel is being paid reparations by Germany on the basis of the accepted six million death toll.[70] Rassinier calls the payment of an indemnity by Germany to Israel “a case of extortion…built up with premeditation,”[71] while App repeats the charge of blackmail and extends it to individual victims, saying that “Claiming such indemnities has probably produced the greatest heyday in history for Jews to commit perjury for one another, and for fraud and lying and cheating on a horrendous scale.”[72] Some deniers even go so far as to claim that the Jewish advisors of World War II leaders like Franklin Delano Roosevelt were planning all along to increase the Jewish death count from the Holocaust; David Hoggan states that advisors like Bernard Baruch and Henry Morgenthau Jr. pushed the Allied strategy of unconditional surrender precisely because “this policy was calculated in any event to produce the greatest possible loss of Jewish lives.”[73] To an outside observer, these claims can seem to provide a solid motive for Jews generally and Israel in particular to exaggerate the death toll of the Holocaust purely for financial gain. The only problem with this neat conspiracy is that it is based – unsurprisingly – on totally incorrect information. According to Shermer and Grobman, “When reparations were made, the amount Israel received from Germany was based not on numbers killed but on the cost to Israel of absorbing and resettling Jews who had fled Germany and German-controlled countries before the war, as well as survivors of the Holocaust who came to Israel after.”[74] One does not need to take the words of Shermer and Grobman on faith, however, as the state of Israel actually made a direct request for reparations from the Four Powers (the US, UK, France, and the USSR) in 1951 which does not relate to the death toll at all:

The government of Israel is not in a position to obtain and present a complete statement of all Jewish property taken or looted by the Germans, and said to total more than $6 thousand million. It can only compute its claim on the basis of total expenditures already made and the expenditure still needed for the integration of Jewish immigrants from Nazi-dominated countries. The number of these immigrants is estimated at some 500,000, which means a total expenditure of $1.5 thousand million.[75]

If anything, the structure of the indemnity would provide an incentive for Israel to exaggerate the number of survivors instead of the number of victims, something which flies in the face of denialist rhetoric. Clearly, the evidence for a massive Israeli hoax meant to blackmail reparations out of Germany is completely without merit. But why do deniers focus so much on it, even though it can easily be refuted? Holocaust scholar Deborah Lipstadt does an excellent job of summarizing why the Israeli reparations conspiracy is so crucial to the denial of the true Holocaust death toll: it provides a rationale for the ‘hoax’, something which undergirds the whole denialist effort; it “harks back to traditional antisemitic imagery” including the association of Jews with “ill-gotten gains”; and it plays on existing hostility to Israel and Zionism as the beneficiaries of global Jewish dominance.[76]

Holocaust deniers also sow the seeds of doubt by questioning the origins of the six million figure – which is only a broad estimate, as we will see below – claiming that it was popularized either before or during the war, when the end total could not have conceivably been known. By making these claims, deniers present the six million number as almost totemic, something which was agreed upon by ‘World Jewry’ before the war and would have been levied as a charge regardless of its factual basis. One such instance comes from the Holocaust ‘skeptic’ David Irving, who relates the story of a former New York governor, Martin Glynn, who had claimed in a 1919 speech (five years after his brief term ended) that “’six million’ Jews were being exterminated” at the time.[77] This speech was a call to protect the Jews of Europe, who were potentially under threat in the chaos following the end of the First World War; it was truly coincidental that the general figure Glynn quoted for the number of Jews potentially at risk was the same as the ballpark estimate of the death toll from the actual genocide of the European Jews. This coincidence has been used by deniers to plant the seed that the ‘six million’ had been planned for decades, but it is nothing more than a fluke of history. Another figure that deniers latch on to is that of Raphael Lemkin, the Jewish writer who coined the term ‘genocide’[78] and someone who raised the alarm about the Holocaust before the end of the war. Deniers claim that Lemkin, in his book Axis Rule in Occupied Europe (1944), “contended that the Nazis had gassed millions of Jews, perhaps as many as six millions.”[79] This was a figure which it does not seem that Lemkin specifically referenced in his book at all; a search of its contents does not turn up any reference to ‘six million’ Jews either dead or at-risk[80], the only mention of gas chambers is in a quote from a Polish journal which described the Nazi means of mass execution[81], and Lemkin’s discussion of Jewish victims states “The number of Jews who have been killed by organized murder in all the occupied countries, according to the Institute of Jewish Affairs of the American Jewish Congress in New York, amounts to 1,702,500.”[82] These are not difficult claims to check, but they do take some degree of effort; deniers rely on the reader’s willingness to accept their assertions at face value without further interrogation.

Now that we have seen how deniers undermine the accepted Holocaust death toll of six million Jews, it is necessary to understand their own calculations of the death toll and their explanations for the massive differences which they have with reputable scholars. Holocaust deniers have posited a wide variety of ‘actual’ death tolls from the Holocaust: Rassinier claims the Jewish death toll was likely between 987,592 and 1,589,492[83], App states that he finds a figure of 200,000 to be “about accurate”[84], Hoggan accepts a figure of 300,000 as reasonable[85] and claims that “Not over 2,000,000 Jews were ever interned by the Germans in concentration camps and it is unlikely that the figure was greater than 1,500,000,”[86] and Verrall echoes Hoggan in stating that the 300,000 estimate is accurate while claiming that “it would have been simply impossible for the number of Jewish casualties to have exceeded a limit of one and a half million.” [87] It is not essential to break down the disparate calculations of each of the various Holocaust deniers[88], as all of their figures are manipulated and falsified; it is useful, however, to explicate how these calculations were generally made and how they fall so short of the true toll of the Holocaust. Most of the denialist calculations rely on two major, and related, factors to explain their low estimates: mass scale – often secret – Jewish emigration from Europe making the Nazi-accessible Jewish population far lower than most estimate it to be, and the deliberate evacuation of Eastern European Jews by the Soviet Union to protect them from the Nazi war machine. Both of these assertions are entirely baseless and can easily be debunked.

First, the bulk of Holocaust denial around the six million figure rests on a foundation myth that the European Jewish population in 1939 and throughout the Second World War was far lower than is commonly estimated, primarily due to Jewish emigration out of the continent. Rassinier, for example, claims that he has “affirmed that a minimum of 4,419,908 European Jews managed to emigrate early enough to escape arrest and deportation to concentration camps,”[89] mostly to Israel, the United States, and other countries in the Western Hemisphere.[90] This emigration focus allows deniers to artificially reduce the Jewish population of Europe before the war to fewer than six million, thus supposedly destroying the mainstream claim that six million were killed by the Nazis. Richard Verrall, for instance, manages to lower the European Jewish population accessible to the Nazis to a mere three million by this emigration misinformation[91], meaning that there is no possibility of even half the accepted death toll being reached. Many of these Jewish emigrants are claimed to have migrated to Israel and the United States, yet this would have been incredibly difficult, if not impossible; in both cases, the immigration authorities covering Israel (Palestine was at the time controlled by the UK) and the United States were not at all interested in allowing Jewish immigrants to enter. The 1924 Immigration Act, still in force during World War II, drastically limited the number of immigrants to the US and specified that most should be from Anglo-Saxon Protestant stock[92]; there were also widely publicized incidents of the American government turning away Jewish refugees, exemplified by the 1939 St. Louis ocean liner incident where over 900 predominantly Jewish passengers were refused entry and sent back to Europe.[93] With respect to Israel, then the British Mandate of Palestine, it was incredibly difficult for the Jews of Europe to gain admittance to the future Jewish state; according to the Jewish Virtual Library, “The gates of Palestine remained closed for the duration of the war, stranding hundreds of thousands of Jews in Europe, many of whom became victims of Hitler’s Final Solution.”[94] These two major supposed destinations for the ‘missing’ Jews of Europe clearly cannot have accepted the millions of Jews that deniers claim emigrated during the 1933 – 1945 period. When Jews did emigrate from European countries in the pre-war period, it is highly likely that they migrated within the European continent, as many Jews from Germany and Austria fled to supposedly safe countries like France and the Netherlands, only to be caught in the Nazi net once the war began.

The other aspect of the ‘numbers game’ that denialists play revolves around the supposed evacuation of Eastern European and Russian Jews deep into the Soviet Union where they would be inaccessible to the Nazis. Hoggan claims, based on a single Soviet source, that “the Soviet Union, by evacuating Jews and by other measures, had saved the lives of at least 3,500,000 European Jews.”[95] This claim has been forcefully debunked in a great deal of detail by the historian Ben-Cion Pinchuk, who states that:

The evidence available concerning the annexed territories suggests that there was no special Soviet policy to aid or facilitate the evacuation of the Jewish community. Approximately two million Jews living in the territories between the Baltic and the Black seas fell victim to a lethal combination of circumstances which prevented their escape by spontaneous flight or planned evacuation. Most of the Jews fell under German occupation or were encircled by German troops during the first few weeks of the war. At the same time, there is no evidence that the Soviet government had a clear plan for evacuation, certainly not a plan that took into account the special dangers facing the Jewish population.[96]

The USSR not only did not have a plan for Jewish evacuation, they actually stymied it in several instances, especially through their forced closure of the Soviet Union’s western border, making certain that Jews who tried to flee to the east would be stopped and turned back into the teeth of the Nazi blitzkrieg.[97] Based on the aforementioned information, it is obvious that the death toll calculations of the Holocaust deniers are baseless and flawed in the extreme, but this does not prove that the accepted totals are correct; for that, one must investigate how reputable historians and statisticians approach the estimation of the Holocaust death toll and why their figures are not exactly in lock-step.

The True Death Toll of the Holocaust

Reputable mainstream historians and statisticians generally use two primary approaches to calculate their estimates of the Holocaust death toll: adding, also known as the direct estimating method, and subtracting, known as the indirect method.[98][99] The adding, or direct estimating, method “sums up the number of victims in concentration camps, extermination camps, through killing squads plus all additional material about killed people,”[100] mostly by using wartime documents to glean a count of actual victims.[101] Raul Hilberg separates the adding method into three segments, roughly corresponding to the broad jurisdictional segmentation of the Nazi bureaucracy: “(1) privation, principally hunger and disease in ghettos, (2) shootings, and (3) deportations to death camps.”[102] For many of these victims, there is no direct evidence of their death, as the Nazis had an explicit policy – Aktion 1005 – to destroy all traces of mass murder through the organized removal of bodies from death camps and mass graves and their subsequent cremation.[103] Despite these attempts at covering up their crimes, there is still extant evidence which allows historians to use the adding method to estimate a death toll; for instance, local Jewish councils kept statistics of deaths by privation for reporting to their German supervisors, the Einsatzgruppen – which shot somewhere between one and two million Jews – kept detailed statistics of their shootings for reporting to the Nazi bureaucracy, and the concentration camp and transportation administrations kept numerical registers of the number of deportations to extermination camps.[104] The main issue with using the addition method is the incompleteness of the contemporary statistics; we only have the documents which survived, and the meticulous counting of the Nazi regime stopped as the war drew to a close.[105] The subtraction method “uses prewar demographics and subtracts emigration, numbers remaining in the camps at liberation, and numbers remaining in areas after the war to estimate the number killed.”[106] The main challenges in this approach involve relying on population estimates which are by their very nature inexact, adjusting the numbers for the changing pre- and post-war borders of Europe, and adjusting for those Jews who died of causes unrelated to the Holocaust.[107] More complicating factors arise when one considers the natural rates of birth, which would increase the population at the same time as millions were being killed off; these statistics are difficult to come by, but can be guessed at to achieve something like accuracy. Several estimates of both pre- and post-war Jewish populations can be seen in Appendix A (Tables V – VII and Figure I); pre-war European Jewish populations were calculated at approximately nine-and-a-half million in 1933[108] and over eleven million in 1942[109] – the latter calculation was made by the Nazis themselves for the infamous Wannsee Conference where the Final Solution was determined.[110] Based on these estimates, it is clear that there would indeed have been more than six million Jews within the reach of the Third Reich, directly disproving the assertions of the deniers. With respect to post-war figures, Tables VI and VII in Appendix A show the drastic decline in world and European Jewish populations in 1949; when used in conjunction with the pre-war estimates, these numbers – gleaned from the 1950 American Jewish Year Book[111] – support the contention that six million Jews were indeed killed by the Nazi regime.

Holocaust historians often use both of these methods – adding and subtracting – and cross-check the results to come to a general estimate of the total number of Jewish deaths from the Holocaust. There are significant complicating factors in all calculations, as “the raw data are seldom self-explanatory, and that their interpretation often requires the use of voluminous background materials that have to be analyzed in turn.”[112] It is important to point out that these death tolls are generally ranges of estimates, something which is “typical for scientific data, necessary when figures have been estimated and cannot be stated with certainty.”[113] Different historians use different sources for their calculations, but most find that somewhere between four-and-a-half and six-and-a-half million Jews died in the Holocaust; the majority of these estimations fall in an even tighter range, between five and six million deaths. The fact that historians and statisticians differ on the exact death tolls they produce is not an invalidation of their work, as denialists would have it; indeed, the opposite is true. According to Deborah Lipstadt, “Complete unanimity among historians regarding an event of such magnitude would itself be highly suspicious. A death toll on which all historians unequivocally agreed would raise legitimate suspicions about the independent nature of their historical research.”[114] In Appendix A below, one will find a series of death toll estimates made by a variety of historians; Table I compares the estimates of four different historians[115], Table II is a comparison of pre-war populations and deaths from Lucy Dawidowicz[116], Table III shows a minimum and maximum number of deaths and is compiled by Yad Vashem[117], and Table IV – from Raul Hilberg – is a breakdown of Jewish deaths by cause[118]. Besides these statistical estimates from after the end of the Holocaust, historians have access to the testimony of several former Nazis who independently corroborate the general death toll of around six million Jews. One such instance of corroboration comes from the testimony of “a former Sturmbannführer in the Security Service, Dr. Wilhelm Höttl,” who testified that Adolf Eichmann “had told him that six million Jews had been killed, four million of them in camps and two million in other ways, particularly in the course of shootings during the campaign against the USSR.”[119] This data, straight from the horse’s mouth so to speak, is ignored and downplayed by deniers as part of their ignorance of contradictory evidence; for people who so often give the Nazis every possible benefit of the doubt by taking them at their word, Holocaust deniers quickly drop that tactic when it comes to Nazi testimony or documentation that disproves their assertions in clear language. Given the robust statistical methods of mainstream Holocaust historians described above, as well as their calculations provided in Appendix A below, it is clear beyond a shadow of a doubt that the answer to the rhetorical question posed by the Holocaust denier Richard Verrall – Did Six Million Really Die? – is an unambiguous ‘yes’.

Conclusion

Holocaust denial – contrary to the opinions of many mainstream historians, pundits, and commentators – is not a major threat to the Republic and will not bring down society if it is allowed to exist; in reality, it is merely a series of pitiful attempts by anti-Semitic pseudo-historians to contradict history and replace it with a false narrative that is easily debunked. Society need not be afraid of these cretins; they do not have magical powers of persuasion which inevitably ensorcell those who do not have a background in history – one should have more faith in his fellow man than that. In fact, many deniers believe that mainstream media sources and historians are afraid of the ‘secret knowledge’ of the denialist camp, an assertion exhibited by our denialist annotator in Figure II of Appendix B.[120] Choosing to stifle the speech of Holocaust deniers is not a solution to the problem of their retrograde ideology. As Justice Brandeis said, the remedy to misinformation and hateful speech is not censorship, it is more speech. In a free society, it is up to those with the requisite knowledge to debunk Holocaust denial and defend the historical truth. Although it may be easier simply to close our eyes and stick our heads in the sand, those actions will not put a stop to the malign rhetoric of denialists. The only way to reduce the salience and spread of these noxious ideas in an era of mass Internet communication is to directly counter their assertions and promote the historical veracity of the Holocaust. Diseases are not cured by ignoring them and waiting for them to just go away, they are cured by medication and treatment and are prevented by vaccines; in the case of Holocaust denial, the cure and vaccine are the same – proper education, historical knowledge, and direct rebuttal of disinformation. People generally do not want to be on the wrong side of the truth and are receptive to historical education, but this requires the hard work of engagement on behalf of the historian. It is up to that august profession to be patient, understand that people will have legitimate questions about the Holocaust, and assume good faith on the part of the public. Although anti-Semitism is not as rare as one would hope, there are not very many people who see the totality of the information on the Holocaust and come away unconvinced; it is up to historians to present that information to the public and directly prove that the lies of Holocaust deniers are just that – lies.

Besides engagement and debunking, another helpful strategy to counter deniers in the modern age is to push back against the widespread use of the Holocaust – a real historical atrocity – as a shorthand for anything that is bad or that one does not like. These facetious and often farcical comparisons only serve the denialists’ ends, as they necessarily cheapen the Holocaust itself.[121] This is not to say that historians should not compare the Holocaust to other genocides, but that they should assert that comparisons to relatively banal politics or events should be avoided at all costs. It is indeed tempting to use the verbiage of the Holocaust to assert that something is bad, but this only helps plant the seeds of doubt in the minds of the public, especially when the term is used to decry something that is not universally agreed-upon as being bad. For instance, it is extremely unhelpful to compare one’s political adversaries to Nazis and their policies to the Holocaust. No matter how much one may dislike a political figure, no one but Hitler was Hitler.

These strategies are useful for countering Holocaust denial in a free society, but it must be said that the censorship of noxious and unpalatable ideas in the public square is the path away from that liberty and towards the totalitarianism of the twentieth century. We must all fight back against that trend and embrace the classical liberal philosophy of Voltaire and Brandeis, the philosophy that informs our Constitution and Bill of Rights. As the late Justice so eloquently said, “If there be time to expose through discussion the falsehood and fallacies, to avert the evil by the processes of education, the remedy to be applied is more speech, not enforced silence.”[122] It would do us all well to take those words to heart.

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Appendix A: Estimates of Holocaust Death Tolls and Jewish Populations

Table I: Estimates of Jewish Death Toll by Country – Reitlinger, Hilberg, Gutman/Rozett, Benz[123][124]

Table II: Estimated Jewish Death Toll by Country – Lucy Dawidowicz[125]

Country	Pre-war Jewish Population	Minimum Loss	Maximum Loss
Austria	185,000	50,000	50,000
Belgium	65,700	28,900	28,900
Bohemia and Moravia	118,310	78,150	78,150
Bulgaria	50,000	0	0
Denmark	7,800	60	60
Estonia	4,500	1,500	2,000
Finland	2,000	7	7
France	350,000	77,320	77,320
Germany	566,000	134,500	141,500
Great Britain – Channel Islands		3	3
Greece	77,380	60,000	67,000
Hungary	825,000	550,000	569,000
Italy	44,500	7,680	7,680
Latvia	91,500	70,000	71,500
Lithuania	168,000	140,000	143,000
Luxembourg	3,500	1,950	1,950
Netherlands	140,000	100,000	100,000
Norway	1,700	762	762
Poland	3,300,000	2,900,000	3,000,000
Romania	609,000	271,000	287,000
Slovakia	88,950	68,000	71,000
Soviet Union	3,020,000	1,000,000	1,100,000
Yugoslavia	78,000	56,200	63,300
Total	9,796,840	5,596,029	5,860,129
Rounded	9,797,000	5,596,000	5,860,000

Table III: Estimated Jewish Death Toll by Country – Yad Vashem[126]

Table IV: Estimates of Jewish Death Toll by Cause – Raul Hilberg[127]

Table V: Estimates of Jewish Populations made by Third Reich at 1942 Wannsee Conference[128]

Table VI: Estimated Jewish Population by Continent – 1949[129]

Table VII: Estimated European Jewish Population by Country – 1949[130]

Figure I: European Jewish Population Distribution – 1933[131]

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Appendix B: Denialist Annotations in Anti-Defamation League Resource Book

Note: The following exhibits are scans from the Seton Hall University Library copy of Hitler’s Apologists: The Anti-Semitic Propaganda of Holocaust “Revisionism”. The annotations were left by an unknown prior reader and showcase some of the common attitudes of deniers when confronted with the historical truth of the Holocaust. They have been appended to this paper so as to preserve them and give real-life examples of the relative commonality of anti-Semitism and Holocaust denial. The annotations – and sometimes the passages they reference – are noted with red markings.

Figure I: Title Page Annotation[132]

Figure II: Annotation on page 12, referencing the lack of mainstream rebuttal of Holocaust denial[133]

Figure III: Annotation on page 28, exhibiting anti-Semitic ideas about Jewish control of culture and media[134]

Figure IV: Annotation on page 47, echoing Nazi propaganda concerning the supposed war of the Jews against the Reich and associating Jews with Soviet Communism[135]

Figure V: Annotation on page 59, exhibiting the racial and political tensions within the Holocaust denial movement (annotator makes racist remark about fellow denialist who is Muslim)[136]

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United States Constitution. Amendment I. Accessed at https://www.constituteproject.org/constitution/United_States_of_America_1992.

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United States Holocaust Memorial Museum. “Jewish Losses During the Holocaust: By Country.” Holocaust Encyclopedia. https://encyclopedia.ushmm.org/content/en/article/jewish-losses-during-the-holocaust-by-country.

United States Holocaust Memorial Museum. “Jewish Population of Europe in 1933: Population Data by Country.” Holocaust Encyclopedia. https://encyclopedia.ushmm.org/content/en/article/jewish-population-of-europe-in-1933-population-data-by-country.

Verrall, Richard. (writing as Richard E. Harwood). Did Six Million Really Die? London: Historical Review Press, 1974. Accessed at https://www.ihr.org/books/harwood/dsmrd01.html.

Vidal-Naquet, Pierre. Assassins of Memory: Essays on the Denial of the Holocaust. Translated by Jeffrey Mehlman. New York: Columbia University Press, 1992.

Whitney v. California, 274 U.S. 357, 377 (1927). Accessed at https://www.law.cornell.edu/supremecourt/text/274/357.

Wistrich, Robert Solomon. “Introduction: Lying about the Holocaust.” In Holocaust Denial: The Politics of Perfidy, edited by Robert Solomon Wistrich, 1-26. Jerusalem: The Hebrew University Magnes Press, 2012.

Yad Vashem. “FAQs. The Holocaust Resource Center.” Yad Vashem – The World Holocaust Remembrance Center. Accessed December 5, 2020. https://www.yadvashem.org/holocaust/faqs.html.

Yad Vashem. “Holocaust Denial Laws and Other Legislation Criminalizing Promotion of Nazism.” Yad Vashem – The World Holocaust Remembrance Center. Accessed December 7, 2020. https://www.yadvashem.org/holocaust/holocaust-antisemitism/holocaust-denial-laws.html.

Yad Vashem. “Murder of Hungarian Jewry.” Yad Vashem – The World Holocaust Remembrance Center. Accessed October 20, 2020. https://www.yadvashem.org/holocaust/about/fate-of-jews/hungary.html.

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[1] US Const. amend. I, accessed at https://www.constituteproject.org/constitution/United_States_of_America_1992.

[2] Brendan O’Neill, “Britain Turns Offensive Speech Into a Police Matter,” Reason.com, Reason Foundation, published September 15, 2018, https://reason.com/2018/09/15/britain-turns-offensive-speech-into-a-po/.

[3] Brooke Kato, “What is cancel culture? Everything to know about the toxic online trend,” NYPost.com, New York Post, published July 10, 2020, https://nypost.com/article/what-is-cancel-culture-breaking-down-the-toxic-online-trend/.

[4] Free Speech Team, “New Poll: Majority of Millennials Support Jail Time for Offensive Speech,” Campaign for Free Speech, published October 23, 2019, http://campaignforfreespeech.org/new-poll-free-speech-under-attack-majority-of-millennials-agree-jail-time-is-appropriate-for-certain-speech/.

[5] Martin Gruberg, “Voltaire,” The First Amendment Encyclopedia, Middle Tennessee State University, 2009, https://www.mtsu.edu/first-amendment/article/1263/voltaire.

[6] Whitney v. California, 274 U.S. 357, 377 (1927), accessed at https://www.law.cornell.edu/supremecourt/text/274/357.

[7] Free Speech Team, “New Poll,” http://campaignforfreespeech.org/new-poll-free-speech-under-attack-majority-of-millennials-agree-jail-time-is-appropriate-for-certain-speech/.

[8] Matt O’Brien, “Facebook bans Holocaust denial, distortion posts,” APNews.com, Associated Press, published October 12, 2020, https://apnews.com/article/election-2020-media-social-media-elections-mark-zuckerberg-14e8073ce6f7bd2a674c99ac7bbfc240.

[9] Yad Vashem, “Holocaust Denial Laws and Other Legislation Criminalizing Promotion of Nazism,” Yad Vashem – The World Holocaust Remembrance Center, accessed December 7, 2020, https://www.yadvashem.org/holocaust/holocaust-antisemitism/holocaust-denial-laws.html.

[10] Conference on Jewish Material Claims Against Germany, “New Survey by Claims Conference Finds Significant Lack of Holocaust Knowledge in the United States,” Claims Conference, accessed October 5, 2020, http://www.claimscon.org/study/.

[11] Conference on Jewish Material Claims Against Germany, “First-ever 50-state survey on Holocaust knowledge of American Millennials and Gen Z reveals shocking results,” Claims Conference, accessed December 7, 2020, http://www.claimscon.org/millennial-study/.

[12] Jewish Virtual Library, “Jewish Population in the United States by State (1899 – Present),” Jewish Virtual Library, American-Israeli Cooperative Enterprise, accessed December 7, 2020, https://www.jewishvirtuallibrary.org/jewish-population-in-the-united-states-by-state.

[13] Conference on Jewish Material Claims Against Germany, “American Millennials and Gen Z,” http://www.claimscon.org/millennial-study/.

[14] Matthew Perrone, “Fact check: ‘Just Say No’ anti-drug campaigns have shown little success in past,” Chicago Tribune, published October 27, 2017, https://www.chicagotribune.com/nation-world/ct-fact-check-anti-drug-campaigns-20171027-story.html.

[15] Conference on Jewish Material Claims Against Germany, “New Survey by Claims Conference,” http://www.claimscon.org/study/.

[16] Conference on Jewish Material Claims Against Germany, “American Millennials and Gen Z,” http://www.claimscon.org/millennial-study/.

[17] United States Holocaust Memorial Museum, “Holocaust Denial and Distortion,” Anti-Semitism and Holocaust Denial, https://www.ushmm.org/antisemitism/holocaust-denial-and-distortion.

[18] Robert Solomon Wistrich, “Introduction: Lying about the Holocaust,” in Holocaust Denial: The Politics of Perfidy, ed. Robert Solomon Wistrich (Jerusalem: The Hebrew University Magnes Press, 2012), 1.

[19] Note: Holocaust deniers often refer to themselves as ‘revisionists’ and their approach as ‘Holocaust revisionism’. This is purposely inaccurate nomenclature and will not be used to describe Holocaust deniers in this paper.

[20] Michael Shermer and Alex Grobman, Denying History: Who Says the Holocaust Never Happened and Why Do They Say It? (Berkeley, California: University of California Press, 2000), xv.

[21] Shermer, Denying History, xvi.

[22] Shermer, Denying History, xvi.

[23] Shermer, Denying History, 114-117.

[24] Anti-Defamation League, Hitler’s Apologists: The Anti-Semitic Propaganda of Holocaust “Revisionism” (New York: Anti-Defamation League, 1993), 59.

[25] Deborah Lipstadt, Denying the Holocaust: The Growing Assault on Truth and Memory (New York: Plume Publishing, 1994), 103-104.

[26] Anti-Defamation League, Hitler’s Apologists, 51-52.

[27] Anti-Defamation League, Hitler’s Apologists, 52.

[28] Wistrich, “Introduction,” 22.

[29] Anti-Defamation League, Hitler’s Apologists, 58-61.

[30] Wistrich, “Introduction,” 21.

[31] Jeffrey Herf, The Jewish Enemy: Nazi Propaganda During World War II and the Holocaust (Cambridge, Massachusetts: Harvard University Press, 2008), 159.

[32] Alain Goldschläger, “The Trials of Ernst Zündel,” in Holocaust Denial: The Politics of Perfidy, ed. Robert Solomon Wistrich (Jerusalem: The Hebrew University Magnes Press, 2012), 112-114.

[33] Anti-Defamation League, Hitler’s Apologists, 54-57.

[34] Wistrich, “Introduction,” 16-18.

[35] Lipstadt, Denying the Holocaust, 31-33.

[36] Lipstadt, Denying the Holocaust, 32.

[37] Lipstadt, Denying the Holocaust, 50-51.

[38] Shermer, Denying History, 40.

[39] Lipstadt, Denying the Holocaust, 51-52.

[40] Lipstadt, Denying the Holocaust, 55.

[41] Anti-Defamation League, Hitler’s Apologists, 5.

[42] Lipstadt, Denying the Holocaust, 142.

[43] Anti-Defamation League, Hitler’s Apologists, 74.

[44] Anti-Defamation League, Hitler’s Apologists, 10.

[45] Lipstadt, Denying the Holocaust, 184.

[46] Shermer, Denying History, 46.

[47] Anti-Defamation League, Hitler’s Apologists, 19-25.

[48] Shermer, Denying History, 49.

[49] Shermer, Denying History, 53.

[50] Lipstadt, Denying the Holocaust, 123-124.

[51] Lipstadt, Denying the Holocaust, 124-125.

[52] Pierre Vidal-Naquet, Assassins of Memory: Essays on the Denial of the Holocaust, trans. Jeffrey Mehlman (New York: Columbia University Press, 1992), 21-23.

[53] Lipstadt, Denying the Holocaust, 104.

[54] Richard Verrall (writing as Richard E. Harwood), Did Six Million Really Die? (London: Historical Review Press, 1974), Chapter 6.

[55] Yad Vashem, “Murder of Hungarian Jewry,” Yad Vashem – The World Holocaust Remembrance Center, accessed October 20, 2020, https://www.yadvashem.org/holocaust/about/fate-of-jews/hungary.html.

[56] Anti-Defamation League, Hitler’s Apologists, 56.

[57] Anti-Defamation League, Hitler’s Apologists, 56.

[58] David Hoggan (writing as Anonymous), The Myth of the Six Million (Newport Beach, California: The Noontide Press, 1969), Chapter 7.

[59] Anti-Defamation League, Hitler’s Apologists, 47.

[60] Anti-Defamation League, Hitler’s Apologists, 28.

[61] Herf, The Jewish Enemy, 7.

[62] Shermer, Denying History, xv.

[63] Lipstadt, Denying the Holocaust, 85.

[64] Austin J. App, The Six Million Swindle: Blackmailing the German People for Hard Marks with Fabricated Corpses (Tacoma Park, Maryland: Boniface Press, 1973), 3.

[65] App, The Six Million Swindle, 2.

[66] Hoggan, The Myth of the Six Million, Chapter 6.

[67] Paul Rassinier, Debunking the Genocide Myth: A Study of the Nazi Concentration Camps and the Alleged Extermination of European Jewry, trans. Adam Robbins (Los Angeles: The Noontide Press, 1978), 160.

[68] Rassinier, Debunking the Genocide Myth, 160.

[69] App, The Six Million Swindle, 2.

[70] Verrall, Did Six Million Really Die?, Introduction.

[71] Rassinier, Debunking the Genocide Myth, 240.

[72] App, The Six Million Swindle, 4.

[73] Hoggan, The Myth of the Six Million, Chapter 10.

[74] Shermer, Denying History, 106.

[75] Shermer, Denying History, 106.

[76] Lipstadt, Denying the Holocaust, 57-58.

[77] David Irving, Nuremberg: The Last Battle (London: Focal Point Publications, 1996), 100.

[78] Lipstadt, Denying the Holocaust, 63.

[79] Hoggan, The Myth of the Six Million, Chapter 6.

[80] Raphaël Lemkin, Axis Rule in Occupied Europe: Laws of Occupation, Analysis of Government, Proposals for Redress (Washington, DC: Carnegie Endowment for International Peace, 1944).

[81] Lemkin, Axis Rule in Occupied Europe, 22.

[82] Lemkin, Axis Rule in Occupied Europe, 89.

[83] Rassinier, Debunking the Genocide Myth, 286.

[84] App, The Six Million Swindle, 24.

[85] Hoggan, The Myth of the Six Million, Chapter 21.

[86] Hoggan, The Myth of the Six Million, Conclusion.

[87] Verrall, Did Six Million Really Die?, Conclusion.

[88] For an example of a detailed – and incorrect – calculation of Jewish dead by a Holocaust denier, see Chapter 14 in Rassinier, Debunking the Genocide Myth, 210-276.

[89] Rassinier, Debunking the Genocide Myth, 278.

[90] Rassinier, Debunking the Genocide Myth, 282.

[91] Verrall, Did Six Million Really Die?, Chapter 3.

[92] Lipstadt, Denying the Holocaust, 35.

[93] Daniel A. Gross, “The U.S. Government Turned Away Thousands of Jewish Refugees, Fearing That They Were Nazi Spies,” SmithsonianMag.com, Smithsonian Magazine, published November 18, 2015, https://www.smithsonianmag.com/history/us-government-turned-away-thousands-jewish-refugees-fearing-they-were-nazi-spies-180957324/.

[94] Jewish Virtual Library, “Immigration to Israel: British Restrictions on Jewish Immigration to Palestine (1919 – 1942),” Jewish Virtual Library, American-Israeli Cooperative Enterprise, accessed December 8, 2020, https://www.jewishvirtuallibrary.org/british-restrictions-on-jewish-immigration-to-palestine.

[95] Hoggan, The Myth of the Six Million, Chapter 7.

[96] Ben-Cion Pinchuk, “Was There a Soviet Policy for Evacuating the Jews?: The Case of the Annexed Territories,” Slavic Review 39, no.1 (March 1980): 54-55.

[97] Pinchuk, “Was There a Soviet Policy for Evacuating the Jews?,” 55.

[98] Shermer, Denying History, 176.

[99] Raul Hilberg, “Appendix B: Statistics of Jewish Dead,” in The Destruction of the European Jews: Third Edition (New Haven: Yale University Press, 2003), 1303-1308.

[100] Shermer, Denying History, 176.

[101] Hilberg, “Appendix B,” 1303.

[102] Hilberg, “Appendix B,” 1303.

[103] Shermer, Denying History, 107.

[104] Hilberg, “Appendix B,” 1303-1304.

[105] Hilberg, “Appendix B,” 1306.

[106] Shermer, Denying History, 176-178.

[107] Hilberg, “Appendix B,” 1306.

[108] United States Holocaust Memorial Museum, “Jewish Population of Europe in 1933: Population Data by Country,” Holocaust Encyclopedia, https://encyclopedia.ushmm.org/content/en/article/jewish-population-of-europe-in-1933-population-data-by-country.

[109] Rudolph Höss, Death Dealer: The Memoirs of the SS Kommandant at Auschwitz, ed. Steven Paskuly (New York: Da Capo Press, 1996), 375-376.

[110] Many Holocaust deniers actually claim that the Wannsee Conference of January 20, 1942 was a fiction. For one such example, see Hoggan, The Myth of the Six Million, Chapter 13.

[111] Leon Shapiro and Boris Sapir, “World Jewish Population,” in American Jewish Year Book, Volume 51, 1950, ed. Morris Fine (New York: The American Jewish Committee, 1950), 246-247. www.ajcarchives.org/AJC_DATA/Files/1950_7_WJP.pdf.

[112] Hilberg, “Appendix B,” 1303.

[113] Shermer, Denying History, 176.

[114] Lipstadt, Denying the Holocaust, 61.

[115] Shermer, Denying History, 177.

[116] Lucy Dawidowicz, The War Against the Jews, 1933-1945 (New York: 1975), 402, quoted in Anti-Defamation League, Hitler’s Apologists: The Anti-Semitic Propaganda of Holocaust “Revisionism” (New York: Anti-Defamation League, 1993), 82.

[117] Yad Vashem, “FAQs. The Holocaust Resource Center,” Yad Vashem – The World Holocaust Remembrance Center, accessed December 5, 2020, https://www.yadvashem.org/holocaust/faqs.html.

[118] Hilberg, “Appendix B,” 1320.

[119] Hilberg, “Appendix B,” 1301.

[120] Anti-Defamation League, Hitler’s Apologists, 12.

[121] Alvin Rosenfeld, “The Perils of Forgetting,” TabletMag.com, Tablet Magazine, published November 7, 2019, https://www.tabletmag.com/sections/news/articles/the-perils-of-forgetting.

[122] Whitney v. California, 274 U.S. 357, 377 (1927).

[123] Shermer, Denying History, 177.

[124] Note that specific citations for each historian’s work can be found in the ‘Note’ section of the image, just beneath the table.

[125] Lucy Dawidowicz, The War Against the Jews, 1933-1945 (New York: 1975), 402, quoted in Anti-Defamation League, Hitler’s Apologists: The Anti-Semitic Propaganda of Holocaust “Revisionism” (New York: Anti-Defamation League, 1993), 82.

[126] Yad Vashem, “FAQs. The Holocaust Resource Center,” Yad Vashem – The World Holocaust Remembrance Center, accessed December 5, 2020, https://www.yadvashem.org/holocaust/faqs.html.

[127] Hilberg, “Appendix B,” 1320.

[128] Höss, Death Dealer, 375-376.

[129] Leon Shapiro and Boris Sapir, “World Jewish Population,” in American Jewish Year Book, Volume 51, 1950, ed. Morris Fine (New York: The American Jewish Committee, 1950), 246.

[130] Leon Shapiro and Boris Sapir, “World Jewish Population,” in American Jewish Year Book, Volume 51, 1950, ed. Morris Fine (New York: The American Jewish Committee, 1950), 247.

[131] United States Holocaust Memorial Museum, “Jewish Population of Europe in 1933: Population Data by Country,” Holocaust Encyclopedia, https://encyclopedia.ushmm.org/content/en/article/jewish-population-of-europe-in-1933-population-data-by-country.

[132] Anti-Defamation League, Hitler’s Apologists, title page.

[133] Anti-Defamation League, Hitler’s Apologists, 12.

[134] Anti-Defamation League, Hitler’s Apologists, 28.

[135] Anti-Defamation League, Hitler’s Apologists, 47.

[136] Anti-Defamation League, Hitler’s Apologists, 59.