Citron v. Zündel I. The Facts This case directly focuses on the application of the Canadian Human Rights Act to communication via the Internet.* Ernst Zündel, the respondent, is a German-Canadian citizen currently living in the U.S. It is alleged that material Zündel has posted on his website, specifically pamphlets and publications that were repeatedly provided on the homepage (ex: “66 Questions and Answers on the Holocaust”), caused repeated telephonic communication that was likely to expose Jews to hatred or contempt. The central thesis of the complaint is that Zündel was engaged in discriminatory practice. II. The Issue Is it a discriminatory practice to post material on a Website is the material is likely to expose a person to hatred or contempt? What limits, if any, are to be applied to repeated communication of hate messages via the Internet? And if applied to the Internet, is this a permissible restriction on freedom of speech under the Charter of Rights and Freedoms? III. The Holding
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