 From 1981 to 1982, Zündel had his mailing privileges suspended by the Canadian government on the grounds that he had been using the mail to send hate propaganda, a criminal offence in Canada.Zündel then began shipping from a post office box in Niagara Falls, New York, until the ban on his mailing in Canada was lifted in January 1983.In 1983, Sabina Citron, a Holocaust survivor and founder of the Canadian Holocaust Remembrance Association, filed a private complaint against Zündel before the Canadian Human Rights Tribunal.