The Fourth Reich: Sex Offender Laws as a Prototype for the Holocaust
By: Derek “The Fallen One” Logue
Written in 2006 [Addendum added Oct. 8, 2013]
Sex offender laws are as old as written history. In the Bible, sexual sins are clearly defined in two of God’s Commandments (Exodus 20:14, 17), and the entire chapter of Leviticus 18. Sexual behavior was one of the key aspects in life that were highly regulated “so that lust and orgiastic urges are controlled and that Israel does not become as carnally bankrupt as its pagan neighbors” (Oxford, 132). Such acts were “abhorrent to The Lord,“ and was among the list of many offenses which was punished by death or banishment. In the New Testament, Jesus Christ would add more sanctions through His teachings, counting lust and divorce amongst the list of sexual sins (Matthew 5:27-32). Saint Paul would call for the excommunication of an incestuous couple (1st Corinthians 5), calls us to “holy purity” in sexual matters (1st Thessalonians 4:3-8), and professes that “ neither fornicators… nor boy prostitutes, nor sodomites…. Will inherit the kingdom of God” (1st Corinthians 6:6-10). Later in the chapter, Paul remind us that whoever we have sexual relations with we “become one flesh” with them (v. 16, cf. Genesis 2:24), and that sexual immorality is unique among sin because it is a sin against your own body, as opposed to all other sins which are external or affecting others (v. 18).
The purpose of the sanctions could be perceived as the same legitimate goals as our current laws against illicit sexual behavior: to deter such behavior from being practiced by citizens of the community, to maintain a certain degree of purity or community integrity, and to punish those who engage in behavior deemed detrimental to the needs and goals of the society at large. However, much like the Levitical laws of purity regarding leprosy (Ch. 13-14), illicit criminal acts or “sins” continued to persist despite the laws. In the Biblical Flood story, Noah and his family were the only ones to survive a devastating worldwide flood. In the very same chapter as the post-flood covenant between God and Noah (Genesis 9) is a story in which Noah passes out from drunkenness and Ham, the father of Canaan, “saw his father’s nakedness,” then told his brothers about it (v.22). Noah would later curse Canaan. The nature of the phrase has been suggested by scholars to imply some form of sexual sin, as the Canaanites were known for certain indecent sexual practices (Oxford, 17). Thus the prevalence of sexual sin and the desire to eradicate such sins have been a common goal of both God and many men and women.
In our modern society, the quest continues to eradicate deviant sexual behaviors. However, recent American laws designed to deter and punish people who perform deviant sexual behaviors, named after children murdered in the course of a sex crime, is neither a modern concept nor is it original, but a pattern that has repeated itself in history. Even within this past century, we had seen a similar pattern take place in, of all places, Nazi Germany. Again, certain groups of people were deemed sexual deviants, branded, isolated, sent to prison, and killed, for the purposes of deterrence and punishment for their deviant acts, and for the sake of integrity and purity of their community.
Children and Nazi-era Nationalism
A quote often attributed to Adolph Hitler in Mein Kampf in many blogs and websites reads as follows:
“The state must declare the child to be the most precious treasure of the people. As long as the government is perceived as working for the benefit of the children, the people will happily endure almost any curtailment of liberty and almost any deprivation.”
The first sentence is a direct quote from page 403 of the Ralph Manheim translation of Mein Kampf (Hitler 1943). The second sentence, however, may have originated in another or an annotated translation (as there are many translations differing greatly on syntax or vocabulary), or a even a commentary on the passage. [See Addendum]
Regardless, the statement is an accurate description of the ideology of Hitler. Hitler’s ideal plan for youth was for “Aryan purity [that] would rescue the fatherland from the shame of defeat and unveil a glorious future” (Epstein and Friedman 2000). Hitler himself stressed the importance of indoctrinating the youth, as can be noted in his following statement:
“[National, or rather, German] self confidence must be inculcated in the young national comrade from childhood on. His whole education must be so ordered as to give him the conviction that he is absolutely superior to others. Through his physical strength and dexterity, he must recover his faith in the invincibility of his whole people.” (p. 411, Hitler 1943)
Indoctrination of the children was typical of Hitler’s ideology, and these principles he believed in were passed on by means of the Propaganda Ministry. Joseph Goebbels was placed in charge of this department, and Goebbels made it clear his goal was the complete reformation of German culture. His “Ministry” initiated the following tasks:
Promoting the German nation as the supreme form of social and cultural organization
Ridding the nation of Jewish influences
Develop the Fuhrer image of Hitler, the ‘faultless leader” to whom all Germans owed allegiance
Encouraging pride in the Aryan race as the highest form of human development
Developing German-Aryan arts free from the corruption of Jewish influences
The negative consequences was a lack of true cultural growth and overbearing political correctness, as such
actions defined German culture by what it was against rather by then what it was for (p. 98 Lynch 2004). Predictable though it may be, Hitler called for a degree of national unification beginning in childhood.
Hitler was quite methodical in his madness. In regard to the “nationalization of the masses,” Hitler declares, “To win the masses for a national resurrection, no social sacrifice is too great” (p. 336 Hitler 1943). Later Hitler contends that only with a “ruthless and fanatically one sided” orientation toward a common goal can this goal be achieved, Id., at 337. “The soul of the people can only be won if along with carrying on a positive struggle for our own aims, we destroy the opponent of these aims… their internal poisoners are exterminated.” Id., at 338. Thus in order to fulfill
his dream of unification, Hitler must awaken the pride of the people by uniting them in a common cause.
The Fall of the “Gay Eden”
Berlin in the 1920s can be described as a “homosexual Eden,” where homosexual practices were accepted as a cultural norm. In Paragraph 175 of the German Penal Code remained the anti-sodomy laws which called for imprisonment and loss of civil rights for bestiality or sex between males of the same sex, but Dr. Magnus Hirshfield, a renowned sex researcher, homosexual, and socialist, led a movement to repeal Paragraph 175 (Epstein and Friedman 2000). Hirshfield headed the “Scientific Humanitarian Committee,” which led the gay rights movement in Germany. The government had tried and failed to pass more restrictive legislation in 1929, which at the time was considered a major victory for gays. Also, the leader of the SA (the sturmabteilungen or “Storm Troop”), Ernst Rohm, was a member of Hirshfield’s League for Human Rights and openly attended homosexual meeting places. Hitler and Heinrich Hemmler defended Rohm against public attacks of anti-Nazi critics, who openly ridiculed Rohm‘s homosexuality (Austin 2006). Hitler hated gays but defended Rohm vigorously as noted in the following statement: “The SA is not an institution for the moral education of Genteel young ladies, but a formation of seasoned fighters… private life cannot be an object of scrutiny unless it conflicts with basic principles of Nationalist Socialist Ideology.” (Epstein and Friedman 2000)
Rohm was the exception to the rule of the Nazis, who ruthlessly persecuted homosexuals. Rohm was also a source of ridicule for those opposed to the Nazis. The fire that burned down the Reichstag building was a critical case in point. The Nazis blamed the communists, but the communists claimed it was one of Rohn‘s gay lovers. Id. Rohm, however, was also Hitler’s major threat to total control over the Reich. Rohm was the voice of the upper class, while Hitler was the working man’s politician. Though Rohm never openly challenged Hitler felt compelled to eliminate Rohm; Hitler had Rohm and top brass at the SA executed in June 1934, in an incident known in history as “The Night of the Long Knives.” (113-4, Lynch 2004).
The Persecution of “Asocials”
Rohm’s execution and the replacement of the SA with the SS (schutzstaffeln, “protective squads”) under the command of Hemmler, Id., began a severe persecution of homosexuals. This would conveniently and effectively remove one of the biggest weapons used by the critics to ridicule the Nazis. Hunts for homosexuals began mainly as a campaign to silence the rumors of Rohm’s “perversions“. Id., at 124-5. The Nazis’ first order of business was to strengthen the existing anti-sodomy law in order to justify their persecution. The original paragraph 175, which was added to the Reich Penal Code in 1871, read as follows:
“An unnatural sex act committed between persons of the male sex or by humans with animals is punishable by imprisonment; the loss of civil rights might also be imposed.”
In 1935, Paragraph 135 was amended to “close legal loopholes;” it now consisted of three parts: Paragraph 175: “A male who commits a sex offense with another male or allows himself be used by another male for a sex offense shall be punished with imprisonment. Where a party was not yet 21 years of age at the time of the act, the court may in especially minor cases refrain from punishment.
- Paragraph 175a: Penal servitude up to 10 years or, where there are mitigating circumstances, imprisonment not less than three months shall apply to:
- A male who, with violence or the threat of violence to body and soul or life, compels another male to commit a sex offense with him or to allow himself to be abused for a sex offense;
- A male who, by abusing a relationship of dependence based on service, employment, or subordination, induces another male to commit a sex offense with him or to allow himself to be abused for a sex offense;
- A male over 21 years of age who seduces a male person under 21 years to commit a sex offense with him or to allow himself to be abused for a sex offense;
- A man who publicly commits a sex offense with males or to allow himself to be abused by males for a sex offense or offers himself up for the same.
- Paragraph 175b: An unnatural sex act committed by humans with animals is punishable by imprisonment; the loss of civil rights might also be imposed.”
In addition, Paragraph 174 forbade incest and other sexual offenses with dependants, and Paragraph 176 outlawed pedophilia. (Austin 2006). It is worth noting that the German word unzucht, translated literally as anal sex, can also mean the broader interpretation “lewdness,” which lead to the possibility of punishing milder acts like mutual masturbation, fondling, or even kissing. This interpretation was used by the Nazis and, later, in the Federal Republic of West Germany (Wikipedia 2006). Even gossip and innuendo- “a touch, a gesture, or a look” was enough to get you arrested (Epstein and Friedman 2000).
In 1933, the Nazis passed the “Dangerous Habitual Criminals and Measures for Protection and Recovery,” a series of restrictions on sex offenders. This laws gave judges the authority to order mandatory castration in cases of rape, defilement, sex acts against children (Paragraph 176), coercion to commit sex offenses (Paragraph 177), the committing of indecent public acts including homosexual acts (Paragraph 183), murder of manslaughter of a victim (Paragraph 223-226), if they were committed to arouse or gratify the sex drive, or homosexual acts with boys under age 14. The Amendment to the Law for the prevention of Offspring with Hereditary Diseases dated June 26, 1935 allowed castration of violators of Paragraph 175 “with consent” (Austin 1996). Castration was a “medically effective way to deal with these people” (p186, Frei 1993).
After Rohm’s execution, Hitler ordered the registration of so-called “asocials;” this task fell upon the infamous “Gestapo” (Austin 2006). Registration of all the citizens of the Reich was a tool deemed necessary by the Gestapo for the promotion and security of their Nationalist ideology (p.117 Frei 1993). The Gestapo (Geheime stuatpolizei, “State Secret Police”) was given immense power. One such power was the power to make laws retroactive, meaning they could make crimes out of actions that were not illegal when they were first performed (117 Lynch 2004). Asocials were taken into “protective custody;” a euphemism allowing “brown shirt gangs” to pick up anyone they chose, since no charges were issued, and held indefinitely. Id., at 148.
On March 9th, 1937, Himmler ordered a round-up of registered “professional and habitual criminals or dangerous sex offenders.” Armed with registration lists, the Gestapo rounded up 2,000 asocials and sent them to the concentration camps. It happened “suddenly and without warning,” and came exactly one year after a round up of the “work-shy.” Among the other “asocials:” Jews with prior criminal records, tramps, prostitutes and pimps, transients, gypsies and “such persons as having numerous previous convictions for resistance, bodily harm, brawling, disturbances of domestic peace or similar and have thereby shown that they do not wish to adapt themselves to the order of the national community.” This practice was perfected in respect to “elements harmful to the people.“ Id. At 104.
During this period about fifty thousand men were convicted of “indecency,” and about fifteen thousand of them were condemned to the concentration camps. Id., at 124. The concentration camps began as “a terrifying development of the Nazi aim of removing from society all those who, for reasons of race, politics, religion, or sexual orientation, were regarded as unfit to live with ordinary Germans,” which included Jews, gypsies, Communists, Jehovah’s Witnesses, and homosexuals. Id. At 148. These camps were filled not just with criminals, but with “people who could not be convicted by normal courts because they had not broken valid law but who were considered socially undesirable (p. 104 Frei 1993)
Sexual deviants were first marked by the label “Paragraph 175,” then later by a pink triangle. Officially, the death penalty was reserved for the Jews and the Roma and Sinti gypsy tribes; the official policy on sexual deviancy was “re-education.” This meant sexual deviants were subjected to castration, slave labor, or human (surgical) experimentation. In addition, like most modern prisons, the sexual deviants were at the bottom of the prison food chain; they were victimized by prison guards and stronger inmates alike. Roughly two-thirds of those who entered the concentration camps died there (Epstein and Friedman 2000). Re-education was a policy of “open-ended punishment,” or what we would refer to as “indeterminate sentencing.” This was designed to more deeply compel the individual to change behaviors for the good of the nation and to no longer be a burden upon the government (p.184-5, Frei 1993)
It is interesting to note that women were, for the most part, spared the sexual deviant label. Unlike men, the Nazis believed sexual deviancy in women was a temporary and curable condition. That is not to say they weren’t without problems, but there were very few cases of women arrest for sex crimes (Epstein and Friedman 2000). However, women were encouraged to learn “respectable behavior,” reject “masculinization” of women, and promote “feminine grace and female charm” (p. 125 Lynch 2004). Many lesbian women thus entered “marriages of convenience” or other ways to mask their criminalized acts (Epstein and Friedman 2000). With all the atrocities taking place in Nazi Germany, it begs the question, “How did the people allow this to happen?” The short answer is the Propaganda Ministry.
The Red and Green Propaganda Machine
In order to convince society to accept the atrocities Hitler was about to unleash on his own people, Hitler created his Propaganda Ministry to handle the public relations campaign. Regarding to the second line I quoted in that phrase attributed to Hitler, (“As long as the government is perceived as working for the benefit of the children, the people will happily endure almost any curtailment of liberty and almost any deprivation”), a look into the actions of the Propaganda Ministry support the concept of the aforementioned statement.
Goebbels, as head of this ministry, had set out to fulfill Hitler’s assertion in Mein Kampf that “the people will more easily fall victims to a great lie than a small one.” Propaganda included the saturation of the media portraying Hitler as the great leader of the Aryan nation (p.102 Lynch 2004). Of course, part of the propaganda involved cooperation among the people to make the nation to Hitler’s Nationalistic ideology. The justification for the myriad of atrocities served a twofold purpose: economic exploitability and the “weeding of inferiors” deemed necessary for the promotion of society. Id., at 105. Himmler gave a clear example of the use of propaganda in the following statement:
“Roughly 7-8% of men in Germany are homosexual… If that is how things remain, our nation will fall to pieces because of that plague. Those who practice homosexuality deprive Germany of the children they owe her…” (Epstein and Friedman 2000).
Nazi ideals of racial purity required the elimination of undesirables (p. 105 Lynch 2004); this social “weeding out” was one of the Nazis’ most important duties. (p. 122 Frei 1994). Powerful as the Gestapo was, they were not large enough to act alone; around 70% of the arrests made by the Gestapo were initiated by the tips or information of the general public. Id., at 118. The Gestapo heavily relied on an intricate network of informants that even included children. Suspected sexual deviants were then arrested and used to fill their registries of real or suspected deviants. Later the registries were used in their sweeps and round-up (Austin 2006).
Most Germans approved of the use of these so-called “cleansing” camps; many saw those taken away as deserving of their punishment, and believing they would come back “all the better.” Of course, the camps were also standing symbols of power to intimidate dissidents. However, most citizens were in the dark about the true conditions of the camps, as the Germans hid the deplorable conditions really well. Some camps were open to visitors such as the Red Cross; these were “model prisons,” where prison conditions were civilized. The camps closed to the public were “hell holes” (p. 148-9 Lynch 2004). Relatively few people, aside from the “suspect classes,” were fully aware or gave thought to the actions of the Gestapo. Before long even mental patients at the asylums knew when the T4 squads retrieved patients for “special treatment,” it meant they were going to be exterminated. Id., at 106.
Even after the fall of Nazi Germany, the indoctrination of society continued to plague “sexual deviants.“ Many of those released from the camps by the Allied Forces were rearrested and sent back to prison to complete their court mandated sentences under Paragraph 175. After the fall of Nazi Germany, the East Germany and West Germany had very different views on Paragraph 175. West Germany retained the full Nazi version of Paragraph 175 until 1969, where prosecution was limited to “qualified cases.” Between 1945 and 1969, some 50,000 were convicted under these laws. Interestingly enough, while homosexuality was still banned in many situations, bestiality was removed from the books. East Germany removed much of the sting of Paragraph 175, but did not abolish it altogether until 1989. (Wikipedia 2006)
America’s WWII “Internment” Camps
America, the so-called “Land of the Free,” was not exempt from the use of concentration camps. On February 19th, 1942, President Franklin D. Roosevelt signed “Executive Order 9066,” which allowed the roundup of 120,000 Japanese-Americans and sent into so-called “relocation centers.” Their only crime? Being Japanese (Siasoco and Ross 2007). Roosevelt justifies this action in the Order itself:
“Whereas, the successful prosecution of war requires every possible protection against espionage and sabotage to national-defense material, national defense premises and national defense utilities…” (Executive Order 9066, as found on www.pbs.org)
“Roosevelt’s executive order was fueled by anti-Japanese sentiment among farmers who competed against Japanese labor, politicians who sided with anti-Japanese constituencies, and the general public,” who were in a state of panic after the Pearl Harbor bombing. Canada also passed a similar policy. (Siasoco and Ross 2007) As in the German concentration camps, US internment camps were overcrowded and living conditions were poor. Many died there, and the only hope for release was by enlisting in the US Army, which less than 1% of “internees” enlisted. Even the US Supreme Court upheld these abominable practices: see Hirabayashi v. US (1943) and Korematsu v. US (1944). In 1944, Roosevelt finally rescinded the order, and not until 1988 did the government decide to make reparations. Other ethnic groups were also sent into these camps or were met with increased restrictions as “enemy aliens.” These groups never received reparations. (Siasoco and Ross 2007)
Comparisons Between American and Nazi Sex Offender Laws
A myriad of similarities can be drawn between American sex offender laws and those laws imposed in Nazi Germany:
Table 1: Comparison between Nazi and American Sex Offender Laws and Practices
Nazi Germany Laws and Practices
- Increased age of consent to 21
- Broad definition of sexual deviancy “lewdness”
- Dangerous Habitual Criminals and Measures for Protection and Recovery: Mandatory or “consensual” castrations
- Gestapo ordered registration of “asocials”
- Gestapo given power to round up suspected sex offenders without a conviction and shipped to concentration camps
- Sex offenders branded with pink triangles or label Paragraph 175
- ”Re-education programs,” increased mandatory penalties for sex offenders, and indeterminate sentencing
- Women sexual deviants rarely punished, encouraged instead to be more feminine: Women can be cured, men are incurable
- Propaganda: “Weeding out inferiors” necessary to promote society and children
- Economic exploitability of sex offenders: civil forfeitures, cheap labor in camps
- Public fear, sex scandals, media propaganda, and use of informants to obtain registries
American sex offender laws and practices:
- Increasing age of consent to 18 in most states
- Broad definition of sexual abuse for minor acts
- Various states have allowed judges to impose chemical castration on child victim or repeat sex criminals (LaFond 2005)
- Megan’s Law: public registration of sex offenders
- Ohio passes first “Civil Registry,” allowing people to be registered as sex offenders without a conviction and subject to penalties
- Alabama sex offender licenses with the words “Sex Offender” in red letters
- Civil commitment programs, increased mandatory penalties for sex offenders, and indeterminate sentencing
- Female sex offenders receive lighter sentences and seen as less severe; all male sex offenders are “pedophiles”
- Banishing sex offenders is “necessary for safety of our youth”
- Economic exploitability: Billions in grants for agencies and private businesses dealing in sex offender monitoring
- Public fear based on misinformation of statistics, sex scandals, media propaganda, and registries make all registrants a suspect class
Most importantly, Hitler implemented a campaign of propaganda. The media promoted the cause in a way not unlike American media portrays sex offenders; this was fueled by public fears and embarrassments, as Rohm was a source of scandal to the Nazis. Furthermore, Hitler found a “common cause” to unite the people: the procreation of the “super race,” and that all acts or traits that deviate from this goal must be eradicated. Fear and disgust over the increase of homosexual activity and promotion in Berlin during the 1920s was more than enough fuel to fan Hitler’s flames of hatred. Once Hitler found acceptance and justification in eliminating one “defect” in society, it opened the door to persecution of other hated groups. The most atrocious acts recorded in our modern history, initiated and justified by the persecution of sex offenders!
People who fail to learn from history are doomed to repeat it. America is so dangerously close to imperialism by virtue of its treatment of sex offenders. Imagine being publicly humiliated and forced to show your face on an internet registry, branded, denied work, denied the right to live anywhere, then being charged with a felony for not being able to find a registered address, being indefinitely confined to a mental institution or a prison as an asocial, and denied a voice, much less a place, in society, as you are not even a recognized group of people, much less as an individual. What has happened in Nazi Germany is happening right here in America! “The Land of the Free!?!” Hitler did not go straight into persecuting the Jews, he first took the path of least resistance then eased into further persecutions. In the same way, America has started the campaign to deprive human rights by depriving the rights of sex offenders who completed their sentences. Even now, the legal system is forming registries of drug offenders, violent offenders, and so forth. The Patriot Act allows us to be randomly searched, and have our personal records and even our phone calls monitored. Such acts are met with little resistance, because the “needs of the general public outweigh the rights of the individual.” Worse, Americans parrot the propaganda of the media, such as the misinformation of sex offender recidivism rates or the actual threat of foreign terrorism. Of course, like the Nazis, we are led to believe the deprivation of human rights is justified by the safety of our children from “trench coat wearing, candy waving, bush lurking trolls” or “Koran thumping, suicide bombing, flag burning terrorists.” Where will it end? And who will be next? Maybe the next victim will be YOU!
- Hitler, Adolph. Mein Kampf. Translated by Ralph Manheim. Houghton Mifflin, New York, Boston, 1943.
- Lynch, Michael. Teach Yourself: Nazi Germany. McGraw-Hill, Chicago, 2004.
- Frei, Norbert. National Socialist Rule In Germany: The Fuhrer State 1933-1945. Blackwell, Cambridge, MA, 1993.
- Epstein, Rob and Friedman, Jeffrey. Paragraph 175. New Yorker Video, 2002. [Video]
Austin, Ben S. Homosexuals and the Holocaust. http:www.mtsu.edu/`baustin/homobg.html. 2006.
- Wikipedia. Paragraph 175. http://en.wikipedia.org/wiki/Paragraph_175. 2006.
- Various. The Catholic Study Bible, 2nd Ed., New American Version. Oxford University Press, 2006.
- LaFond, John Q. “Preventing Sexual Violence: How Society Should Cope With Sex Offenders.” American Psychological Association: 2005.
- Siasoco, Ricco Villanueva and Ross, Shmuel. “Japanese Relocation Centers.” http://www.infoplease.com/spot/internment1.html. 2007.
- Roosevelt, Franklin D. Executive Order 9066 (1943) Published by The Children Of The Camps Project, Satsuki Ina. 1999.
Report Created December 18th 2006
Last Edited July 22nd, 2007
This report © 2006 Derek “The Fallen One” Logue
ADDENDUM Oct. 8, 2013
I wrote this article in the fall of 2006. Since that time, it has been duly noted that the infamous passage by Hitler was not penned by Hitler. Instead, the passage was contained within a fictional letter written in the style of CS Lewis’s “The Screwtape Letters” by Rabbi Daniel Lupin. Rabbi Daniel Lapin is an Orthodix rabbi, radio personality, and author of America’s Real War. The fictional letter is called “Adolph Hitler,” and was previously published in The American Enterprise, Nov/Dec 1999.
You can find a copy of this letter HERE: http://www.aapsonline.org/brochures/lapin.htm
The entire paragraph from which the quote was extracted is found below. I find the full passage even more compelling than the shortened quote we are used to seeing:
Finally, dear Julius, you will remember what I frequently said and wrote in Mein Kampf: “The state must declare the child to be the most precious treasure of the people.” I explained that as long as the government is perceived as working for the benefit of children, the people will happily endure almost any curtailment of liberty and almost any deprivation. It is truly heartwarming to see how well this lesson has been learned by the American government. In the name of children, incursions into the private lives of American citizens have been made that we Nazis would have gazed at with open-mouthed admiration. Does it matter that our bodies failed as long as our spirit still triumphs?
This is quite an interesting passage. Sex offender laws, the PATRIOT ACT, and a myriad of similar laws have undermined the Constitution in recent years, and have been successful because the Government uses child safety to pass laws that erode human rights. The ignorant masses have bought this argument hook, line, and sinker.
While the passage was not an actual quote by Hitler, it is in line with Hitler’s philosophy, which I stated in my 2006 article.