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Sorry for the late response.
I agree that there are atrocities that have ‘beaten’ the holocaust, but I don’t see how that’s relevant. The Mongol Empire isn’t a threat. The resurgence of fascism and the misguided glorification of Nazism is. These countries have made laws that are addressing what that happened to *them* in hopes that *their* civilization does not get hijacked again.
Saying that one ‘cannot criticize the holocaust’ without punishment is misleading (and requires rewording, imo). Is mere criticism of the (most widely accepted version of holocaust events) enough to land you in prison? Could one be arrested in Germany for making the following statement?:
* In my opinion, the number of deaths in the Holocaust has been exaggerated by 500,000.
I don’t know the answer to that. But I don’t believe criticism is illegal, just denial or gross misrepresentation. It’s not like you get a week in the pokey if you say the H word. How the law is enforced is another matter, but I think the laws’ scope is much narrower than that. https://en.wikipedia.org/wiki/Laws_against_Holocaust_denial
edit: People have been arrested in Germany for saying, “Heil, Hitler!”, but that’s context/intent dependent.