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At age 70, David Irving, the world's most infamous and intransigent Holocaust denier, continues to flirt with more prison time in a series of European nations over his revisionist claims about World War II. And he is not alone.

In early December, Irving appeared on a British television show, claiming there is "not a single document linking Hitler with decisions on the Holocaust, except negative decisions." (In 2006, Irving served six months of a prison term in Austria for "trivializing, grossly playing down and denying the Holocaust.")

Then on Dec. 18, Spanish police recorded a speech Irving gave at the Europa bookstore, a well-known neofascist haunt, in Barcelona. Investigators said they intended to carefully examine the speech to determine whether Irving's lecture could "incite xenophobia or justify genocide," a crime punishable by prison time in Spain. Fewer than 20 people attended the speech as more than 100 protesters rallied outside.

Also in December, Irving made a controversial appearance in a film celebrating the 60th anniversary of the Universal Declaration of Human Rights. On Dec. 9, Irving appeared on UK television in "An Independent Mind," a documentary by Jewish filmmaker Rex Bloomstein. The director told TotallyJewish.com, a UK news website, that he agonized over the decision to include Irving. But he added: "Irving is someone who reflects the limits of freedom of expression. He epitomizes repellent views which make us aware of the limits of freedom of expression. It would be derelict not to include someone who challenges how we look at that freedom."

The Norwegian Festival of Literature had previously approached Irving in the same spirit to invite him to speak at the well-attended literary festival in May 2009. Festival chairman Jesper Holte said his intention was "to invite a liar and a falsifier of history to a festival about truth, and confront him with this." After controversy erupted over Irving's scheduled appearance last fall, however, the festival rescinded the invitation.

That same month — October 2008 — Australian Holocaust denier Fredrick Töben was arrested at London's Heathrow airport en route from the U.S. to Dubai. Töben was taken into custody by British authorities who planned to extradite him to Germany to face pending charges of Holocaust denial, which in that country is a crime punishable by up to five years in prison. Töben served time in a German prison in 1999 for the same offense.

German prosecutors sought Töben's arrest on grounds that the website of Töben's Adelaide Institute published Holocaust denial statements, including claims that accounts of Nazi gassings were "outright lies." Over the past decade, Töben, a schoolteacher, has gained a number of admirers on the Holocaust-denial circuit. In 2001 and 2003, he spoke out about his beliefs at "Intifada Conferences" held in Iran, where government authorities routinely deny the Holocaust.

Not long after Töben was arrested in London, a British judge ruled that the international warrant for his arrest was invalid because it contained only "vague and imprecise" details about Töben's alleged denial. On Nov. 20, German prosecutors dropped their appeal of that British court ruling, and Töben was released the same day. Back home in Australia, Töben awaits a contempt-of-court hearing for allegedly refusing to comply with a court order to remove all Holocaust denial claims from the Adelaide Institute website.