Description of Incident: The Canadian Human Rights Commission ruled that the social benefits of elimintating hate speech outweigh the issues of protection of free speech. The CHRC stated, "we now know that the internet is not a 'lawless zone' and cannot be used to promote hate."

Results of Incident: Zundel was forced to "cease and desist" from using his website. Zundel is currently facing deportation to Germany because of an alleged immigration violation.