Hate on the Net
The Nuremberg Files website serves as a prime case study of online extremism but does not reveal the tremendous scope of extremist usage of the Internet. Today, in addition to radical anti-abortionists, a wide range of other extremist groups, including hate groups of all kinds and anti-government groups, have taken to cyberspace. Though it is difficult to gauge precisely the extent of the extremist presence online, hundreds of extremist websites currently exist, and their numbers seem to be growing at an explosive rate.1
Historically, extremist groups have used print media of all kinds, including pamphlets, magazines, newspapers, books, and posters as vehicles of propaganda. And extremists have never failed to exploit new forms of electronic communication. So, in the past, extremists have used broad-band and short-wave radio, audiotape, videotape, and cable television to push their views. The advent of online extremism in the Internet age was, then, a matter of course. Extremists use websites, email, and online forums to communicate with one another and disseminate propaganda.2
Through the use of such online facilities, some of the limitations of traditional media and real life encounters may be overcome. Through the World Wide Web, material can be published to a global audience quickly, easily, and inexpensively. In addition to text, sound, images, and video may be included to enhance the visual appeal and communicative capabilities of extremist websites. Facilities such as email lists, newsgroups, and other online forums allow extremists of similar persuasions to meet in cyberspace, thus defying the restrictions of geographic isolation. And online forums not dedicated to extremism provide the opportunity for extremists to unleash messages upon unsuspecting and largely captive audiences around the world. Due to the highly anonymous character of the Web and most online forums, online extremists can cast off the inhibitions which come with being personally linked to ones words. Material which one would hesitate to seek out, order, or posses in the real world for fear of public exposure can be anonymously accessed in cyberspace. Through email, extremists who meet in online forums may continue their correspondences in private, using cryptography to ensure security if so desired. And extremists can use email to anonymously threaten specific individuals.3
Today on the Internet, an astounding array of extremist positions find expression. In 1996, the Anti-Defamation League (ADL) published The Major Vehicles and Voices on Americas Far-Right Fringe an extensive catalog of real world extremist groups and individuals.4 By 1997, almost half of the individuals and groups listed in the report had established themselves on the Internet.5 Considering the extent of online extremism led the ADL in 1997 to identify the presence of a Web of Hate:
Well-known bigots and hate groups and publications the Ku Klux Klan, The Spotlight (house organ of Willis Cartos Liberty Lobby, the largest anti-Semitic propaganda organization in the United States), incendiary neo-Nazi William Pierce and his National Alliance, as well as David Duke, probably Americas best-known and most politically active racist are active on the Web. Holocaust deniers, peddling anti-Semitism through pseudo-history ... have been particularly eager to embrace this new technology. ... Militias, common law court activists, modern-day secessionists ... are also using the Internet. Add to that a number of neo-Nazi skinhead and white-power music sites, Web pages operated by Identity churches, those hate groups masquerading as religions, as well as a number of independent haters located in the U.S. and countries around the world, and what emerges is a Web of Hate, a nexus of extremist propaganda that pollutes the social and political environment.6
The summary of the extremist presence on the Internet given here is extensive but by no means complete. Types of extremism the ADL fails to touch on include the hatred of gays and various religious groups. As exploring all parts of the Web of Hate in any detail would be infeasible, three particular areas (which overlap to varying degrees) will be considered in what follows: those occupied by white supremacists, Holocaust deniers, and anti-government groups.
White supremacists have established a very substantial presence on the Internet. In 1995 Don Black, a former leader of the KKK, created Stormfront, the first major white supremacist website.7 Today, many other racist sites not too dissimilar from Stormfront exist. Hence, Stormfront may be examined to reveal the nature of the large class of sites to which it belongs.
Stormfront includes a library of articles espousing social, political, and historical views consistent with the sites general themes of hate and bigotry. The library includes such titles as: White Power: Weve Got It, Equality: Mans Most Dangerous Myth, Destructive Immigration, and What World Famous Men Said About the Jews. In addition to this extensive collection of racist propaganda, Stormfront contains discussion forums with titles such as Strategies and Tactics and White Activists, facilities for joining Stormfronts mailing lists, a calendar of upcoming events for white patriots, a collection of white supremacist graphics, and an archive of audio and video clips of public addresses made by well known racists. Additionally, the site includes an extensive list of links to hate-related sites and pointers to hate-related Usenet newsgroups such as alt.politics.nationalism.white and alt.skinheads. Stormfront also links to the websites of organizations from The Other Side. Among these is a link to the Anti-Defamation League, which is characterized as the oldest organization fighting to suppress facts harmful to Jewish Interests. In sum, the Stormfront site is suggestive of the incredible depth and breadth of white supremacy online.
One current extremist movement closely linked to white supremacism is Holocaust denial. Holocaust deniers claim that the accepted historical account of the Holocaust is false or inaccurate, a myth propagated by the Jews; they claim, in particular, that millions of Jews were not systematically exterminated by the Nazis. Today on the Web, numerous sites can be found containing propaganda pieces posing as historical analyses which invoke falsehoods, distortions, and fallacious logic in arguing for the Holocaust deniers story. The response to the questions What about Auschwitz? Is there any proof that gas chambers were used to kill people there? found in 66 Questions and Answers on the Holocaust from the Institute for Historical Reviews website typifies the language of Holocaust denial:
No. Auschwitz, captured by the Soviets, was modified after the war, and a room was reconstructed to look like a large gas chamber. After Americas leading expert on gas chamber construction and design, Fred Leuchter, examined this and other alleged Auschwitz gassing facilities, he stated that it was an absurdity to claim that they were, or could have been, used for mass executions.8
The most overt danger of Holocaust denial on the Internet is the possibility that people might be deceived by the air of historical authority conveyed by revisionist propaganda found online and led to wholly or partially accept its claims. And, of course, Holocaust denial has anti-Semitic overtones offensive regardless of the extent to which the story of denial is believed. As the ADL writes, ...the Holocaust deniers propaganda insinuates subtle but hateful anti-Semitic beliefs about Jews as exploiters of non-Jewish guilt, and as controllers of academia or the media.9
In response to the emergence of Holocaust denial on the Internet, a number of sites have been created which give genuine historical accounts of the Holocaust and explicitly refute claims of the deniers. The Nizkor Project, for example, contains extensive documentation and analysis of the real facts of the Holocaust, direct refutation of holocaust denial, including the correct answers to the Institute for Historical Reviews 66 Questions, and an exposition of the methods and tactics of denial.10 Another site dedicated to telling the real story of the Holocaust is the Holocaust History Project.11 In addition to numerous essays about the Holocaust, the site contains pictures and translations of primary documents from the Holocaust.
Anti-government militia groups represent another form of extremism common to the Internet. Such groups often espouse elaborate theories of governmental corruption, conspiracy, and crimes against the people, and anticipate the need for armed conflict with the forces of a government bent on depriving the American citizenry of freedom and constitutional rights. A passage from the Militia Declaration of the Minuteman Press website exemplifies anti-government rhetoric found online:
Should any Citizen be injured, or suffer loss of life, now or in the future, by unlawful authority, and/or without due process, or if any action is taken against any signer, their families, or any supporter of this Declaration, it will be considered an act of war against the Citizens of all States. We will then no longer restrain our brethren form the use of whatever force is necessary to eliminate the threat of unlawful federal enforcement authority.12
Not surprisingly, anti-government websites commonly reveal a particular interest in guns, explosives, and military tactics. The website of the Montana Unorganized Militias is a case in point.13 The site contains recommendations for the acquisition of firearms and munitions, instructions for fortifying the defenses of ones house, links to suppliers of military equipment, and information about tactical warfare strategy. And, perhaps most disturbingly, the site has a list of Lethal Links to pages which give detailed bomb-making instructions.
Thus far we have primarily considered expressions of extremism conveyed through websites. One notable feature of extremism on the Web is that, by and large, one must do something special, whether that is typing in a known URL, clicking on a series of links, or using a search engine, to come into contact with it. Unsolicited extremist email, on the other hand, can be thrust upon an unsuspecting recipient who did nothing to seek it out.14
In one incident reported by the ADL, 58 students at the University of California at Irvine, mostly Asian-Americans, received an E-mail demanding that they leave the campus or, the writer warned, I personally will make it my life career to find and kill everyone (sic) of you personally.15 Other email attacks have targeted far more recipients. For example, in the Crusader Spam attack of 1995, thousands of mailing list subscribers received anti-Semitic email messages just prior to Rosh Hashanah and Yom Kippur.16
It is sometimes possible to track down the perpetrators of email hate. For example, one Richard Machado was implicated in the incident at Irvine and charged with the commission of a hate crime.17 Technically savvy hatemailers, however, can escape detection through such techniques as forging email headers and using anonymous remailers. Despite efforts to find an electronic trail to the source of the Crusader Spam, the culprit in that case was never identified.18
Extremist propaganda attacks are also commonly directed at Usenet newsgroups and other online forums. By posting messages to newsgroups, messages of hate can be inflicted on a worldwide audience. Even if users refuse to read the body of such posts, the subject headers, often filled with racist slurs and typed in capital letters, cannot be ignored. As in the case of email, the extremist spammer can employ technical tricks to avoid being tracked down.
Much of the material distributed on the Internet by haters and other extremists would no doubt strike most people as utterly offensive, abhorrent, and despicable. Material admitting to the application of such descriptors, however, has nevertheless enjoyed the protection of the First Amendment. According to legal precedent, the First Amendment prohibits, with certain important exceptions, the suppression of speech based on its content. The absolute repugnance of the content of the speech in question has not been found to constitute an exception. As quoted in the ruling of a federal appellate court in the case of Robert v. Collins, Under the First Amendment there is no such thing as a false idea. However pernicious an opinion may seem, we depend for its correction not on the conscience of judges and juries but on the competition of other ideas.19
One notable feature of much extremist speech online is the advocacy of violence or other illegal activity. The question of the protection afforded such speech by the First Amendment was considered by the Supreme Court in Brandenburg v. Ohio. In this case the Court overturned a statute outlawing the advocacy of the duty, necessity, or propriety of crime, sabotage, violence, or unlawful methods of terrorism as a means of accomplishing industrial or political reform.20 The statute had been used to prosecute members of the KKK for advocating violence against Blacks and Jews. It was ruled that Freedoms of speech and press do not permit a State to forbid advocacy of the use of force or of law violation except where such advocacy is directed to inciting or producing imminent lawless action and is likely to incite or produce such action.21 Given this decision, most of the advocacy of unlawful acts propagated by extremists on the Internet receives First Amendment protection.
Of course, the fact that certain types of extremist speech are not protected by the First Amendment should not be neglected. Speech which meets the imminent lawless action criteria of Brandenburg v. Ohio, though relatively rare, may be silenced by the courts. And, as in the case of the Nuremberg Files and the sending of death threats through email at the University of California at Irvine, threatening speech may be unlawful as well. See our legal analysis of the Nuremberg Files for a further discussion of true threats.
Given that the law imposes relatively few restrictions on extremist speech in cyberspace, the question arises of what non-legal mechanisms of opposition exist. One such mechanism is the regulation of content by Internet Service Providers, discussed in the next section. Additionally, parents may regulate their childrens exposure to online extremism through the use of filtering software. A number of products are currently on the market which may be used to block access to sites and newsgroups with offensive or inappropriate content. Among these is the ADLs HateFilter which forbids access to sites which preach hate and directs users who attempt to access such sites to educational material on the nature of hate. Perhaps the most powerful means of opposing the influence of extremism online is the proliferation of information over the Internet which raises awareness about the tactics of online extremists and refutes their fallacious claims. The sites mentioned above dedicated to setting the record straight about the Holocaust epitomize this tactic. Whatever the case may be, it is clear that extremist groups have discovered and taken advantage of the opportunities provided by online media, and for the time being at least, are here to stay.
1 High Tech Hate: Extremist Use of the Internet. Anti-Defamation League. 1997. Nexis. Roberts, Regina. Group Takes Aim at Cyberhate. The Atlanta Constitution. 25 Nov. 1997. Nexis. For an extensive listing of hate sites, see: Franklin, Raymond. The Hate Directory: Hate Groups on the Internet. Accessed on: 11 Mar. 1999. http://www.bcpl.lib.md.us/~rfrankli/hatedir.htm
2 High Tech Hate: Extremist Use of the Internet. Anti-Defamation League. 1997. Nexis.
7 High Tech Hate: Extremist Use of the Internet. Anti-Defamation League. 1997. Nexis. Stormfront. Accessed on 11 Mar. 1999. http://www.stormfront.org/
8 66 Questions and Answers on the Holocaust. Institute for Historical Review. 1998. Accessed on: 11 Mar. 1999. http://www.ihr.org/leaflets/66qna.html
9 Hate on the World Wide Web: A Brief Guide to Cyberspace Bigotry. Anti-Defamation League. 1999. Accessed on: 11 Mar. 1999. http://www.adl.org/special_reports/hate_on_www/www_holocaust.html
10 The Nizkor Project, Accessed on: 14 Mar. 1999. http://www.nizkor.org/
11 The Holocaust History Project, Accessed on: 14 Mar. 1999. http://www.holocaust-history.org/
12 Militia Declaration. Minuteman Press Online. 1999. Accessed on: 11 Mar. 1999. http://www.afn.org/~mpress
13 Montana Unorganized Militias. Accessed on: 11 Mar. 1999. http://www.angelfire.com/mt/shootin
14 High Tech Hate: Extremist Use of the Internet. Anti-Defamation League. 1997. Nexis.
16 High Tech Hate: Extremist Use of the Internet. Anti-Defamation League. 1997. Nexis. Loureed Digest. Vol. 2, Issue 33. October 1, 1995. Accessed on: 11 Mar. 1999. http://www.rocknroll.net/loureed/digest/DigestV2.33.html
17 E-mail Is Becoming a Conduit of Prejudice on Many Campuses. The New York Times. February 16, 1997. Nexis.
18 High Tech Hate: Extremist Use of the Internet. Anti-Defamation League. 1997. Nexis.
19 United States Court of Appeals for the Seventh Circuit. Collins v. Smith. 578 F.2d 1197. 1978. Nexis.
20 Supreme Court of the United States. Brandenburg v. Ohio. 395 U.S. 444. 1961. Nexis.