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===Scholars=== {{See also|Irving v Penguin Books and Lipstadt}} 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.<ref>{{cite book |author-link1=Wilhelm Heitmeyer |first1=Wilhelm |last1=Heitmeyer |first2=John |last2=Hagan |title=International Handbook of Violence Research |publisher=Springer |year=2003}}</ref> The 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."<ref>Deborah Lipstadt, 1992 interview with Ken Stern of the American Jewish Committee</ref> 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.<ref name=66-q&a>{{cite web|title=Holocaust denial – The IHR's Questions & Answers, and Nizkor's Responses|url=http://www.nizkor.org/features/qar/qar00.html|work=[[Nizkor Project]]|access-date=September 28, 2013|archive-url=https://web.archive.org/web/20131202230742/http://www.nizkor.org/features/qar/qar00.html|archive-date=December 2, 2013|url-status=dead}}</ref><ref>{{cite book |first1=Robert L. |last1=Hilliard |first2=Michael C. |last2=Keith |title=Waves of Rancor: tuning in the radical right |publisher=M.E. Sharpe |year=1999 |isbn=0-7656-0131-1 |page=250}}</ref><ref>{{cite book |first1=Daniel |last1=Wolfish |first2=Gordon S. |last2=Smith |title=Who Is Afraid of the State?: Canada in a World of Multiple Centres of Power |publisher=University of Toronto Press |year=2001 |isbn=0-8020-8388-9 |page=108}}</ref> In December 1991 the [[American Historical Association]], the oldest and largest society of historians and teachers of history in the United States, 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."<ref name=":0" /> 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.<ref name=":0">{{cite web |url=http://www.historians.org/perspectives/issues/1991/9112/9112RES.CFM |title=AHA Statement on Holocaust Denial |archive-url=https://web.archive.org/web/20100201141606/http://www.historians.org/perspectives/issues/1991/9112/9112RES.CFM |archive-date=February 1, 2010 |publisher=[[American Historical Association]] |access-date=October 11, 2013}}</ref> The AHA has also stated that Holocaust denial is "at best, a form of academic fraud".<ref name="adaaha">{{Cite book |last1=Gerstenfeld |first1=Phyllis B. |last2=Grant |first2=Diana Ruth |title=Crimes of hate: selected readings |publisher=[[SAGE Publications]] |page=190 |year=2004 |isbn=0-7619-2943-6}}</ref> Literary theorist [[Jean Baudrillard]] described Holocaust denial as "part of the extermination itself".<ref>Golsan, 130</ref> Holocaust survivor and Nobel Prize winner [[Elie Wiesel]], during a 1999 discussion at the [[White House]] in Washington, D.C., called 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."<ref>{{cite web |url=https://www.pbs.org/eliewiesel/resources/millennium.html |title=Millennium Evening with Elie Wiesel |work=[[PBS]] |date= April 12, 1999 |archive-url=https://web.archive.org/web/20230405050622/https://www.pbs.org/eliewiesel/resources/millennium.html |archive-date=April 5, 2023}}</ref> 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 the book, Lipstadt 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". In 1996, Irving filed a libel suit against Lipstadt and her publisher, [[Penguin Books]]. Irving, who appeared as a defense witness in [[Ernst Zündel]]'s [[R. v. Zundel|trial]] in Canada, and once declared at a rally of Holocaust deniers that "more women died in the [[Chappaquiddick incident|back seat of Edward Kennedy's car]] than ever died in a gas chamber at [[Auschwitz concentration camp|Auschwitz]]",<ref>{{cite web |title=Irving v. Lipstadt |url=http://www.hdot.org/trial |website=Holocaust Denial on Trial |access-date=September 29, 2010 |url-status=live |archive-url=https://web.archive.org/web/20100927204545/http://www.hdot.org/trial |archive-date=September 27, 2010}}</ref> claimed that Lipstadt's allegation damaged his reputation. 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.[96] [[University of Cambridge|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. After a two-month trial in London the trial judge, [[Charles Gray (judge)|Justice Charles Gray]], issued a 333-page ruling against Irving, which referred to him as a "Holocaust denier" and "right-wing pro-Nazi polemicist".<ref>{{cite web |last=Bazyler |first=Michael J. |title=Holocaust Denial Laws and Other Legislation Criminalizing Promotion of Nazism |url=http://www1.yadvashem.org/yv/en/holocaust/insights/pdf/bazyler.pdf |website=International Institute for Holocaust Studies |publisher=[[Yad Vashem]] |access-date=September 29, 2010 |url-status=dead |archive-url=https://web.archive.org/web/20111105153114/http://www1.yadvashem.org/yv/en/holocaust/insights/pdf/bazyler.pdf |archive-date=November 5, 2011}}</ref> [[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.<ref>{{Cite web |url=http://www.protocol.gov.bc.ca/protocol/prgs/obc/1995/1995_KMcVay.htm|website=Order of British Columbia |title=Biography: Kenneth McVay |access-date=June 30, 2008 |archive-url=https://web.archive.org/web/20080516081625/http://www.protocol.gov.bc.ca/protocol/prgs/obc/1995/1995_KMcVay.htm |archive-date=May 16, 2008 |url-status=dead}}</ref>
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