Reevaluating Shoah: Contemporary Responses to Holocaust Restitution Lawsuits

Review Essay

Reevaluating Shoah: Contemporary Responses to Holocaust Restitution Lawsuits

Itamar Levin and Natasha Dornberg, The Last Deposit: Swiss Banks and Holocaust Victims’ Accounts (Santa Barbara: Praeger Trade, 1999).

Michael Bazyler, Holocaust Justice: The Battle for Restitution in America’s Courts (New York: New York University Press, 2005).

John Authers and Richard Wolffe, The Victim’s Fortune: Inside the Epic Battle Over the Debts of the Holocaust. (New York: HarperCollins, 2002).

Ronald W. Zweig, German Reparations and The Jewish World: A History of the Claims Conference. By Ronald W. Zweig. (Kentucky: Routledge, 2001. 248 pages.)

Jeffrey Herf, Divided Memory: The Nazi Past in the Two Germanys (Cambridge: Harvard University Press, 1999).

Michael R. Marrus and William A. Schabas, Some Measure of Justice: The Holocaust Era Restitution Campaign of the 1990s (Madison: University of Wisconsin Press, 2009).

Roger P. Alford and Michael Bazyler, Holocaust Restitution: Perspectives on the Litigation and Its Legacy (New York: New York University Press, 2007).

Reinhold Billstein, Karola Fings, Anita Kugler, and Nicholas Levis, Working For The Enemy: Ford, General Motors, And Forced Labor In Germany During the Second World War (New York: Berghahn Books, 2004).

Oliver Rathkolb, Revisiting the National Socialist Legacy: Coming to Terms with Forced Labor, Expropriation, Compensation, and Restitution (New Jersey: Transaction Publishers, 2004).

Martin Dean, Constantin Goschler, Philipp Ther, eds., Robbery and Restitution: The Conflict over Jewish Property in Europe. By Martin Dean, Constantin Goschler, Philipp Ther, eds. (New York: Berghahn Books, 2008).

John K. Roth, Holocaust Politics (Kentucky: Westminster John Knox Press, 2001).

Elazar Barkan.The Guilt of Nations: Restitution and Negotiating Historical Injustices (Baltimore: The Johns Hopkins University Press, 2001).

Konrad Kwiet and Jürgen Matthaus, eds., Contemporary Responses to the Holocaust (Santa Barbara: Praeger Press, 2004).

David Patterson and John K. Roth, eds., After-Words: Post-Holocaust Struggles with Forgiveness, Reconciliation, and Justice (Washington: University of Washington Press, 2004).

Stutthof, the last Nazi concentration camp left in operation located in a wooded area east of the Polish port city of Gdańsk, was finally liberated by the Allies in early May of 1945. As the final survivors left this camp, few had any inkling that over sixty-five years later, individuals and organizations would continue to debate how to bring justice for the crimes that would become known as Shoah, or the Holocaust, an event so dramatically horrific that it would continue to cause deep divisions among people as they attempted to process, conceptualize, and understand it.

For their part, the triumphant Allies faced tremendous obstacles to this task. In the aftermath of the Second World War and the near immediate emergence of the Cold War, the United States, in particular, never explicitly stated where restitution stood as part of their postwar policies. The goal of rebuilding Germany’s government took immediate precedence, and by encouraging Aryanizers to be part of early efforts in the restitution process, they failed to address the obvious conflict of interest that emerged.[1] Aside from the geopolitical considerations, the sheer number of Jews murdered and the degree of willingness for individual countries to forget their role in the robbery of assets also created significant impediments to reparations efforts.

Although attempts at reparations went on through the Cold War era, the fall of communism allowed some survivors and their heirs new opportunities to seek restitution, despite the long delay. Around this same time period in the early 1990s, Western European societies also reexamined their roles in the destruction of European Jewry with the release of Cold War archival documentation. What followed were an ambitious number of legal and political negotiations, culminating in settlements with Swiss Banks, German industrial companies, European insurance agencies, French and Austrian banks, and the creation of several historical commissions. In the aftermath of this flurry of activity, numerous books have been published attempting to chronicle it and draw out lessons.

One key issue surrounding this literature is the targeting of corporations as the object of reparations for past crimes of theft and genocide.  Clearly, many lawsuits are aimed at organizations, rather than people, simply because most of the remaining individual Nazis that perpetrated the war crimes are deceased. From a methodological standpoint, the problem that emerges is that many of the corporations the Nazis used in order to perpetrate the Holocaust are considered substitutes or surrogates to which recompense can be extracted, instead of legitimate actors that are guilty of war crimes themselves. Initially, this may have been done out of expedience, as Holocaust lawsuits necessitated at least a baseline cooperation between the accused organizations, lawyers, survivor groups, and the courts. In the literature, however, this idea of the corporation as an actor that can be responsible for war crimes, surfaces repeatedly. Although it is not explicitly mentioned, this concept is particularly compelling when it comes to dealing with American corporations’ alleged ties to genocide, as the legal status of such organizations constitutes a “legal person” with, at least theoretically, the same rights and responsibilities as their human counterparts.[2] Therefore, the argument can be made that several of the corporations accused, whose parent companies are American in origin, do not share the same statute of limitations that human beings do and are still subject to lawsuits involving war crimes. The texts reviewed in this essay demonstrate that the related lawsuits do not address the issue of “corporate personhood” even though the legal strategy of extracting justice via financial compensation from an institution, like a bank, when the majority of the perpetrators of genocide are now deceased, naturally lends itself to this particular argument. To put this point another way, the authors of these texts have missed an opportunity to look at the legal framework that allows an organizational perpetrator to continue to operate without reproach long after the human perpetrators that instrumentalized it are gone. Additionally, and perhaps more importantly, some corporations continue to behave in similar patterns as they have during the Holocaust. Armaments manufacturing corporations, for example, can easily flood weapons into many unstable parts of the world, keeping the specter of genocide close at hand.

Informed by a variety of different methodological and ideological orientations, the field of Holocaust restitution history has yet to find an organizational coherence; however, one can discern some common features and influences. This essay will attempt to extrapolate these features while simultaneously drawing out and examining the problem posed by corporate actors. In the group of texts detailed here, two rough categories emerge: First, several texts deal with Holocaust restitution from a journalistic point of view, chronicling the individual cases, involved personalities, and circumstances. The second group is concerned with theoretical interpretations and debates over how to deal with Holocaust-related crimes. Before diving into this second group, which lends itself to a foray into the realm of thorny legal arguments and even less clear philosophical debates, we will examine the more straightforward accounts of the first category.

In this group, The Last Deposit by Itamar Levin and Natasha Dornberg details the story of Jewish Swiss bank accounts that were either expropriated by the Nazis or kept in Switzerland after victims of the Holocaust failed to claim them. When the authors wrote this book in the late 1990s, negotiations between Swiss banks and various Jewish claimant groups were still ongoing and Levin argued that more pressure was needed in order to bring resolution to Holocaust restitution claims. Books of this type were often used as boosters for the various suits, providing a detailed chronological (though less empirical) account of the struggles for restitution and end with an appeal for support for the continuing claims. Because of their vested interest in arousing sympathy for the restitution suits, books like The Last Deposit not only contain highly judgmental language, but unconsciously place themselves in the “uniqueness of the Holocaust” school identified by A. Dirk Moses and exemplified by the work of Steven T. Katz and Yehuda Bauer.[3] This approach is utilized in order to elevate the importance of the Holocaust to argue the importance of the successful resolution of the restitution suits.

In Holocaust Justice,Michael Bazyler has written a similar account to the Last Deposit, tracking the various lawsuits by Holocaust claimants through the late 1990s and into the first few years of the twenty-first century. Essentially, Bazyler argues that the actions were justified and that the various corporations involved received fairly light penalties in the amount of restitution they were forced to pay in comparison with their crimes. Many in Europe considered Holocaust restitution blackmail, and in response Bazyler produces balanced indictments for the individual companies’ behavior. Bazyler credits the swift action by lawyers who prosecuted the various forced labor cases with Germany, and various Austrian and French banks for the Holocaust survivors, which he contrasts with the ongoing and slow process of settling the Swiss bank accounts and life insurance claims. In the latter case, Bazyler argues, in a somewhat bitter fashion, that attorneys were excluded from the process.

Aside from the trial lawyers, Bazyler makes the innovative argument that the American legal system was the main positive force in the Holocaust restitution, providing “the best-and often the only viable- forum in which such claims can be litigated” (251). Bazyler’s work is more far reaching than simply retelling the story of Holocaust litigation; he convincingly argues that the lawsuits were instrumental in the creation of historical commissions, which provided a strategic framework for other restitution movements. As a concluding theme, Bazyler argues that the Holocaust restitution movement has, in part, inspired these other movements. In sum, Bazyler comes closer than Levin and Dornberg in indicting corporations themselves for Holocaust-era war crimes, but still falls short in looking at their behavior as a historical phenomenon in and of themselves.

Largely bereft of historical analysis, John Authers and Richard Wolffe in their book, The Victim’s Fortune,have produced a highly detailed narrative account of the restitution proceedings. This is more of a work of journalism than history, which has the potential to be a useful primary source in the future but does little to ground the reader in the larger histories of Nazi plunder or reparations for the Holocaust. Its over-wrought style threatens to backfire and lend credence to the argument that reparation attempts resulted in opportunism, chaos, and ultimately unsatisfying results for the survivors of the Holocaust. Much like The Last Deposit, the text blurs the line between contemporary history and journalism to such a degree that it renders most of its conclusions of recent events contingent on a much longer view, which will only be obtained well into the future.

German Reparations and The Jewish World by Ronald W. Zweig, also falls into the category of “activist” literature,mainly presenting a narrative account in order to argue for resolution of various lawsuits. Although this text only covers reparation efforts immediately following World War II through the mid-1960s, the timing of its publication at the turn of the twenty first century when interest in Holocaust restitution peaked was precipitous. Zweig’s account is overwhelmingly positivist in tone, and despite his established aim to examine the actual effects of reparations on Jewish communities, Zweig does more to detail interagency cooperation than examine the actual resulting application of the aid money.

Because the text is acutely preoccupied with numerous and varied dollar values of reparations, Zweig’s text risks becoming far more useful to opponents of future Holocaust restitution claims, rather than demonstrating the successes of earlier reparation efforts. For instance, Peter Hayes has rebutted the targeting of corporations for Holocaust restitution arguing, “Billions and billions of dollars have already been extracted from Germany…Now that these victories have been won, however, the time has come to take stock of the collateral damage.”[4] Hayes rightly isolates a “fixation on corporate profits.” A casual read of Zweig’s text would seem to indicate Hayes assertion by the figures that permeate the text; however, one of the facts that neither Hayes nor Zweig prefers to accentuate gets only a brief mention: 70 percent of the initial postwar “payments” to Israel in these early settlements came in the form of West German-made goods, which both provided a boost to the West-German economy and helped rehabilitate its image (79).[5]

Although Zweig demonstrates that reparations negotiations in the 1950s between the Conference on Jewish Material Claims and the German government were difficult and often contentious, they were by no means crippling to Germany. Large sums were paid, but the story is more complicated than Zweig lets on or that Hayes repeats. The danger is that in less discerning hands, Zweig’s preoccupation with dollar values could be damaging to future claims against corporate perpetrators, whose involvement is still being debated.

The final text in this group of narrative accounts is Divided Memory by Jeffrey Herf. The author constructs a political history comparing Holocaust memory in West Germany to East Germany. For West Germany, Herf focuses on the rehabilitation of Nazis as a mixed blessing of both avoiding a right-wing resurgence but also as an act of burying the past. Meanwhile, Herf argues that East Germany clamped down on Holocaust remembrance. Additionally, he demonstrates, as John K. Roth does in Holocaust Politics, which will be examined in the latter category, that Holocaust memory both added to external support for Israel in the West German case, and ideological blindness in the East German support of Palestinian causes. While Herf’s work comes closer to historical analysis akin to the Bazyler text detailed earlier, these are essentially geopolitical histories that gloss over the involvement of transnational corporations in the Holocaust. Even though they are constant protagonists in this collection of texts, the authors never make the jump to analyzing their own significance in collaborating with the Nazis to perpetrate war, theft, and genocide.

The category of theoretical interpretations of Holocaust restitution, in turn, is a much larger group and contains more widely varied approaches. As far as organization is concerned, the one conspicuous detail that becomes apparent is that a majority of the books in this category are collections of essays. Considering the wide range of opinions on Holocaust restitution, this organizational strategy makes sense; however, it also makes the texts challenging to review as a whole or classify within larger literary groupings.

In a more recent work, Some Measure of Justice by Michael Marrus, provides a sharp counterpoint to the positive view of financial awards resulting from Holocaust restitution cases examined in the previous texts. While Bazyler, for example, applauds Holocaust restitution litigation and the attorneys that were involved in this process, Michael Marrus stands at the opposite end of the spectrum. Marrus is highly critical of the restitution cases, and worries that “monetizing justice” has more negative outcomes than positive ones. Marrus concludes with an overriding ambivalence to the possibility of undoing historical wrongs, putting him at odds with many of the other authors discussed here. One distinctive element to his argument that stands in particularly stark contrast to the other texts is his dismissal that corporations should be included in the list of perpetrators. For Marrus, only people can be guilty of perpetrating genocide. This argument stands in direct opposition to much of the litigation against banks and industrial concerns, verging on reproducing their own legal defenses.

Among other people, Edwin Black, a journalist that has written several books about corporate collusion with Nazi Germany, has attacked Marrus for this line of reasoning, questioning Marrus’ motives in an environment where many corporations were hiring historians to defend their past actions.[6] Even more problematically for Marrus and giving some credence to Black’s claims, Marrus announced in his acknowledgement that Some Measure of Justice was funded in part by the Ford Foundation, a charitable organization linked specifically to a corporation that was subject to a Holocaust reparation lawsuit in the forced labor case of Iwanowa v. Ford Motor Company. While the Ford Foundation has had many critics espousing the charity’s various alleged agendas since its founding in 1936, it is safe to assume that the organization exists in part to create a positive and philanthropic image for Ford Motor Company, which exposes a troublesome conflict of interest for Dr. Marrus.

Holocaust Restitution, edited by Roger P. Alford and Michael Bazyler, is a large collection of essays typical of this category. Its division is similar to other works, separating its themes based on the various types of restitution cases: forced labor claims, disgorgement of Holocaust-era accounts from various banks, insurance claims, and recovering looted art. While these themes have become familiar in the historiography, two unique elements from this book are worth mentioning. First is the contribution of an essay by Stuart Eizenstat, who was one of the more directly involved participants in the lawsuits as a State Department envoy during the Clinton administration. Eizenstat’s job was to seek resolution to a variety of long-standing Holocaust restitution cases, which provides an insider account to balance out many of the other claimant-oriented arguments in the text.[7]

The other unique contribution to the text is an argument against restitution by historian Peter Hayes. The premises for Hayes’ claim, as detailed earlier, is that corporate profits during the Holocaust were fairly limited and restitution lawsuits only confuse Holocaust history by hyping corporate malfeasance. As with Michael Marrus, Hayes argument is problematized by claims that he has received funding from an organization on the list of the accused corporations.[8]

While receiving support from an organization in order to access its archives is uncontroversial, in the context of Hayes assertion that corporations were wrongly accused in general because of their supposedly modest profit margins directly contradicts other recent historical work, such as Working for the Enemy by Reinhold Billstein, Karola Fings, Anita Kugler, and Nicholas Levis. The argument regarding compensation for forced labor is best exemplified in this collection of essays, in which a substantial portion of the text is dedicated to the personal testimony and experiences of former forced laborers working for Ford and General Motor’s German subsidiaries. The authors argue that American management of its subsidiaries was continuous throughout Nazi rule and post-war profit recovery was maximized. In one of the more shocking passages in the text that stand in stark contrast to Hayes’ argument that Nazi-era corporate profits were limited, Anita Kugler demonstrates that not only did GM recover its profits from its German subsidiary, Opel, after the war, but it also billed the U.S. government over $100 million dollars for damages caused by the Allies during the war (75). In judgment of the collaborative activities detailed in this book, historian Hans Momsen noted, “securing the growth of the respective companies was reached at an intolerably high moral price.”[9] As mentioned earlier, former forced laborers sued Ford in the U.S., who in turn had their lawsuits dismissed because they were outside the purview of national restitution settlement efforts.

In contrast to Working for the Enemy, the text Revisiting the National Socialist Legacy is presented in a more traditional academic format. This collection of essays is derived from the 2001 conference hosted by the Bruno Kreisky Archives Foundation on Holocaust-Era Assets. Edited by Oliver Rathkolb, the essays provide a thorough and scholarly discussion of the role and limits of national historical commissions, in both their political and social compositions, which form a kind of contemporary debate over the Nazi Past. These discussions are highlighted by the tensions described between historical scholarship, media coverage and politics surrounding the resolution of Holocaust restitution suits.

One interesting feature Revisiting the National Socialist Legacy is the essay by Jean-Francoise Bergier, for whom the commission to investigate the activities of Swiss banks was named after. Bergier has reservations about the contradictory nature of the word “neutrality” and how it was used by Switzerland and other places during World War II. Although he does not specifically name American corporations, a read of the commission’s finding hints that there is more to be learned from the declassification of American intelligence documents related to them.[10] In his essay, Bergier also laments the public perception of historians as the ultimate arbiters of historical judgment for Holocaust-related crimes (48).

Robbery and Restitution, edited by Martin Dean, Constantin Goschler, and Philipp Ther, is another collection of essays that focuses mainly on creating a comparative framework in order to analyze the theft of Jewish property in various European locales. In the group of essays that deal with restitution in the final section of the book, the essayists, such as Gerard Feldman and Jürgen Lillteicher, do a decent job of guiding the reader to the main factors that led to the impetus for settlement: the end of the Cold War, litigants utilizing the American legal system, and the self-examination of Western European societies of their own role in the Holocaust via historical commissions. The more forceful calls for further research are focused on the impersonal mechanisms that deprived Jews of their property, rather than the restitution litigation (262-3). In this framework of expanding beyond the Nazis into the transnational organizations they utilized to plunder Jewish assets, Robbery and Restitution comes a bit closer to the original problem posed by this essay in integrating corporations into the framework of Holocaust-era war crimes.

Moving away from academic discussions and into the theoretical sphere, John K. Roth seeks to create a philosophical framework in his monograph, Holocaust politics. Roth’s philosophical questions revolve around the historical interpretation as it relates to the memory of the Holocaust. While Roth is in the “uniqueness of the Holocaust” camp, he concludes that education about the event can have a constructive conscious-raising effect and create awareness of future injustice (284). How this process would actually work is left fairly vague in the text. In the same vein, Roth allows the text to meander with very little framework. Memory is an understandably difficult subject to nail down, but Roth attempts this subject without much evidence of an organizing methodology.

Coming closer to overarching framework in which memory of the Holocaust could lead to the development of human rights is Elazar Barkan’s The Guilt of Nations.

Barkan’s book utilizes a purposefully wide scope, taking the idea of Holocaust restitution as a possible settlement for historical injustices and transforming it into a political model of “ethical globalization” (88). Barkan explores the typologies of apology, reparation, and restitution with a dose of cynicism, noting that these could be seen as an inexpensive way for the powerful to project the image of just governance while maintaining their hegemony (347-9). This admission sets the Barkan text apart from those like John Roth’s Holocaust Politics, who puts a much more idealistic spin on the positive effects of Holocaust restitution.

In yet another collection of essays, Konrad Kwiet and Jürgen Matthaus in Contemporary Responses to the Holocaust have sought to uncover the inadequacies in explanations for the Holocaust, which they argue has limited the development of historical memory of the event. This standpoint is exemplified by the essay written by Yehuda Bauer, who argues for the uniqueness of the Holocaust compared to other genocides, citing the limitations of language skills by historians in investigating and describing the depth of the tragedy (12-13). Several other contentious issues are addressed by various authors in the text, such as Peter Novick and Norman Finkelstein’s contention that the Holocaust is negatively instrumentalized in contemporary politics. Other unique features not found in other aforementioned texts include a comparative analysis of Holocaust-related films.

What is conspicuously missing from this text aiming to collect contemporary responses to the Holocaust are accounts of the restitution lawsuits of the 1990s. Although an essay from Ronald Zweig is included, who has contributed to the literature on contemporary Holocaust restitution efforts, the work chosen for this collection is focused solely on restitution efforts that followed in the immediate years after the conclusion of World War II.

As with many other books discussed here, After-Words, edited by David Patterson and John K. Roth, is a collection of essays that deals with various responses to Holocaust memory. Rather than focusing specifically on restitution, the authors look at contemporary views within the Jewish community of processing Holocaust grief, anger, and dysphoria. By far the most theoretical of the works presented here, After-Words is much more akin to other recent histories utilizing the “memory turn,” such as the World War I history on bereavement, 14-18: Understanding the Great War by Stephanie Audoin-Rouzeau and Annette Becker. Presented in a point-counterpoint format, After-Words debates the relationship of the Holocaust to Jewish identity. While the text does not go into detail on any particular restitution case, the overall exploration of Jewish reconciliation and forgiveness for the Holocaust resonates strongly with the other material on restitution presented here.

In the realm of what could be considered the end point to the prosecution of Holocaust-era crimes and the beginning of a post-Holocaust era, Lawrence Douglas aptly posed this question in Holocaust Justice: “If the greatest achievement of the restitution effort was the precedent it created for future movements, how salutary is this legacy? Is the check-book the most efficacious tool for settling historical wrongs and reckoning with traumas of the past?” Considering the nearness of the restitution suits from the perspective of history writing, more time is needed to fully assess the implications of Douglas’ question; however a few observations can be made: First, the lack of coherence in the field, far from being negative, demonstrates a great diversity in responses to draw upon, both inside and outside the Jewish community. Second, the consensus that recent Holocaust lawsuits have brought to the fore a new flowering of Holocaust scholarship is self-evident; as an emerging historiography, the field shows great potential for growth. Third, the growth of human rights scholarship is a highly positive development to which the Holocaust history, by extension, helped in part to bring about.

But how does the historiography presented here measure up to the initial question posed by this essay? Are corporations actually being included as valid actors in Holocaust scholarship? Based on the group of works here, there is little evidence to suggest the growth of such a model of scholarships; however, there are a few exceptions. Working for the Enemy provides a good example, both by laying responsibility at the feet of the organizations in question on a functional level, as well as using the contemporary device of oral history to provide a human-scale view to the story of corporate collaboration with the Nazis. Robbery and Restitution also approaches this framework, albeit on a more theoretical level.

Why is the focus on corporations so important? Access to weapons manufacturing, bureaucracy, and capital can easily increase the likelihood of genocide in tyrannical regimes. As this body of Holocaust-era history has taught us, these events can happen quickly and with unprecedented brutality. Behind the tanks, planes, gas, and bullets lie rationally planned businesses. On the other side of this coin lie financial corporations, who, within the context of the literature presented here, have shown every bit as much duplicity, capriciousness, and recalcitrance as their industrial counterparts. Once these organizations have been provided agency as independent actors in their own right, perhaps a more holistic view of the Holocaust can be obtained.

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[1] Presidential Advisory Commission on Holocaust Assets in the United States, Plunder and Restitution: The U.S. and Holocaust Victims’ Assets-Report to the President of the Presidential Advisory on Holocaust Assets in the United States (Washington D.C.: U.S. Government, 2000) SR-172.

[2] Morton J. Horowitz, “Santa Clara Revisited: The Development of Corporate Theory,” in Warren J. Samuels and Arthur S. Miller, eds., Corporations and Society: Power and Responsibility (New York: Greenwood Press, 1987),16-19.

[3] A. Dirk Moses, “Conceptual blockages and definitional dilemmas in the ‘racial century’: genocides of indigenous peoples and the Holocaust.” Patterns of Prejudice, Institute for Jewish Policy Research, Vol. 36, No. 4 (2002) 12-14.

[4] Peter Hayes, “Corporate Profits and the Holocaust: A Dissent from the Monetary Argument,” in Roger P. Alford and Michael Bazyler, Holocaust Restitution: Perspectives on the Litigation and Its Legacy (New York: New York University Press, 2007), 197.

[5] “Treaties: Amends,” Time (Sept. 22, 1952). http://www.time.com/time/magazine/article/0,9171,822468,00.html [accessed Dec. 16, 2010]. See also Sonja Mekel, “Nahum Goldmann: Court Jew without a Court?” H-Net Online, (Oct. 2009). http://www.h-net.org/reviews/showrev.php?id=25718 [accessed Dec. 16, 2010].

[6] Edwin Black, “Michael Marrus falters badly in Some Measure of Justice,” The Cutting Edge News, March 1, 2010. http://www.thecuttingedgenews.com/index.php?article=11999&pageid=&pagename= [accessed Dec. 16, 2010]. See also Barry Meier, “Chroniclers of Collaboration; Historians Are in Demand to Study Corporate Ties to Nazis,” The New York Times, Feb 18, 1999, C1. In the late 1990s many corporations ramped up their legal and historical defenses against accusations, creating a market for researchers willing to work with these institutions.

[7] It is also worth noting that Eizenstat produced his own memoirs of his experience. See Stuart Eizenstat,  Imperfect Justice: Looted Assets, Slave Labor, and the Unfinished Business of World War II (New York: Public Affairs, 2007).

[8] Peter Hayes, Industry and Ideology: IG Farben in the Nazi Era (Cambridge, Cambridge University Press, 1987). Hayes claims to receive ancillary support from IG Farben is on the acknowledgments page, xx.

[9] Hans Mommsen, “Review: Working for the Enemy: Ford, General Motors, And Forced Labor In Germany During the Second World War,” The International History Review, Vol. 23, No. 4, (Dec. 2001), 970.

[10] Independent Commission of Experts Switzerland,  Switzerland, National Socialism and the Second World War (Zürich: Pendo Verlag GmbH 2002), 524.