R. v. Zundel is the only criminal prosecution of a Holocaust denier in the common law world. As we have seen, this complicated life for trial judge Hugh Locke, whose controversial refusal to take judicial notice of the Holocaust was grounded on common law norms of adversarialism. But this was not Locke’s only difficult ruling. Throughout the trial, he had to fit prosecution and defense evidence about the Holocaust into the strictures of the common law rule against hearsay. This chapter outlines the hurdles Locke faced, the solutions he reached, and the problems his solutions created.