May 7th, 2021

Dear members of the Editorial Board,

We, the undersigned, are a group of researchers dealing with contemporary history, memory,
heritage studies, and digital humanities, as well as representatives of civil society in Croatia. We are
writing to you out of concern for the misuse of your journal’s and Institute’s reputation by two
authors who have recently published in IEEE Access, Nikola Banić and Neven Elezović. Their
article, titled “TVOR: Finding Discrete Total Variation Outliers Among Histograms” (IEEE Access
9 (2021): 1807-1832) is being misused by its authors to publicly promote Holocaust and genocide
distortion and denial in Croatia. We do not question the journal’s peer review, nor are we qualified
to challenge the proposed algorithmic method. However, we would like to bring to your attention
the deceitful decontextualization and the public misuse of your journal’s image that Banić and
Elezović have engaged in.

We feel obliged to draw your attention to two major issues – one methodological and the other
ethical – concerning the use of dataset of the Jasenovac camp victims, discussed in the article. First
of all, the official title of the list used in the article is the “Holocaust Survivors and Victims
Database – List of Individual Victims of Jasenovac Concentration Camp.” In the article itself,
however, including the diagrams’ titles, the authors decided – without any explanation – to rename
the list of victims into a “list of inmates”. This implies that not everyone in the list was killed or
died in the camp. This opens up the potential for misuse of the results of this analysis in the media,
an issue which we will address later. The authors are ignoring the historical context and specificities
of different lists/datasets used for mathematical calculation. The levels of completeness of such
datasets differ vastly due to a number of historical circumstances, especially due to the destruction
of evidence by the perpetrators before the end of the war. Additionally, the authors do not explain
the long and complicated process of compiling the Jasenovac Victims List after the war.1 They both
disregard the historical complexities, the origin and the different types of sources used for
compiling it.

The main methodological error in the authors' experimental setup lies in comparing the lists that
significantly differ from each other but are misrepresented in the article as if they were similar. In
the conduct of the experiment, the authors take the German census of 1939 as “a gold standard for
the discrete total variation of the population histograms for that time.” Since the National Socialist
government of Germany conducted the census in a logistically structured way and within a limited
time frame where citizens provided information for themselves and their family, the collected data
were accurate and precise. In contrast to that, the Jasenovac Victims List was collected in a span of
72 years, and victims' birth years have often been difficult to reconstruct since whole families and
villages perished. This fact could explain the higher number of round birth years ending with zero,
since they were likely rounded up due to lack of precise information. From a historiographical
perspective, such specificities of Holocaust and genocide victims' lists are well known. In that
sense, the results of the TVOR method, according to which the histogram of Jasenovac Victims List
contrast the smoothness of the histogram for the German census of 1939, are entirely irrelevant.

Here we move to the second issue with the article, namely, the ethical issue of using sensitive
historical datasets. Although this may not be obligatory for an article published in a STEM journal,
the very use of sensitive data on human victims requires consideration of basic ethical principles
that have been elaborated within the emerging transdisciplinary field of digital humanities (see, for
example, the work of authors such as Todd Presner). Automation bias, structural determinism and
“bad data” practices have been critiqued and elaborated upon from the viewpoint of numerous
humanities and social sciences (see Daly et al., Good Data). The critiques hold true especially in
1
Ivo Goldstein. Jasenovac (Zagreb: Fraktura, 2018), pp. 726-727, 732.
relation to the study of historical phenomena, in which data models always address only some of the
facets of the complex interactions that usually inform the study of the past.

With regards to the abovementioned issues, we must draw your attention to the fact that one of the
authors of the article published in IEEE Access journal, Nikola Banić, has spent years falsely trying
to prove, against mainstream historiographical consensus, that Jasenovac was not a concentration
camp where mass killings were committed and that the list of victims is falsified. As we will show,
this sort of public political engagement is directly related to the authors’ decision to include the list
of Jasenovac camp victims in a big data statistical survey, in order to “prove” Banić’s earlier
unscientific claims. While they did not – and could not – openly claim this in the article itself (they
only point to “potentially problematic parts of a sample”), Banić and Elezović reserved the value
judgment and interpretations for the Croatian public sphere, where they use your journal’s name to
lend credence to their own genocide denial and distortion.

Almost immediately after IEEE Access published their research, Banić and Elezović reached out to
far-right media in Croatia, claiming that they had “mathematically proven” that the list of victims of
Jasenovac is fabricated. Hrvatski tjednik, Croatia’s largest far-right weekly, ran it as their cover
story on February 4th 2021. The title page includes your journal’s logo alongside the false claim that
the IEEE Access article proves that the list of victims of Jasenovac is falsified. Additionally, Banić
and Elezović appeared on the far-right podcast Velebit, making the same claim based on your
journal’s authority and credibility. The entire article from Hrvatski tjednik is now available online
through Kamenjar, a prominent website of the extreme right. The falsified interpretation of the
findings has also been republished in an entire network of Croatian far-right online publications that
peddle Holocaust denial and conspiracy theories, including narod.hr (twice), Croativ, Dragovoljac,
Braniteljski portal, and Bez cenzure. All of them but the last one refer to your journal as the source
of the “scientific proof” that the list of victims of Jasenovac is fabricated. The news was also
published in English by the well-known Croatian nationalist émigré Ina Vukić on her website.

After the research of Banić and Elezović was discussed on Croatia’s national television (once again
misrepresenting mathematical research as having historiographical validity), they began an
orchestrated pressure campaign aimed at Nataša Mataušić, a renowned historian and the President
of the Administrative Council of the Jasenovac Memorial Site. Along with a number of notorious
Croatian Holocaust and genocide deniers, they have also contacted the Ministry of Culture and
Media, the Ministry of Croatian Veterans, and the Ministry of Justice, urging them to take action
regarding the supposed fabrication of the list of victims of the Jasenovac concentration camp, which
they claim was proven by an article in IEEE Access. The appearance of the Croatian historian Ivo
Goldstein on a popular talk show has resulted in an open letter by Matko Marušić, a doctor of
medicine and an associate of Elezović and Banić, publicly accusing Goldstein of lying about the
Jasenovac concentration camp. It is clear that they intend to continuously use the article from IEEE
Access to misrepresent and discredit the work of professional historians.

Banić and Elezović knew that their conclusion, based on faulty historiographical methodology and
intentional misinterpretation, would not be accepted for publication by any reputable historical
journal. Therefore, they have decided to abuse your journal by publishing the research under false
pretenses and then misuse it in the Croatian public sphere in order to make negationist claims about
genocide in the fascist Independent State of Croatia during the Second World War. This constitutes
a grave breach of academic ethics, specifically of IEEE journal guidelines regarding falsification as
well as the IEEE Code of Ethics, which prohibits discrimination according to race, religion, and
national origin, among other things. Although the falsification is not overtly present in the article
itself, the authors are clearly and intentionally engaging in falsification in the public sphere. They
have knowingly and intentionally deceived both your journal and the general public: the journal’s
editorial board was led to think that they are merely presenting an article on the TVOR model, with
no indication it would be used for any other purposes, while the Croatian public is being led to
believe that the article is in fact about the Jasenovac concentration camp, and that it was on these
premises that IEEE Access had published it.

For all of these reasons, we, the undersigned, consider that a reaction from your journal is
warranted. In particular, we would appreciate if you could publish this letter in full in the next issue
of the journal, alongside your own statement, if you may so wish. We leave entirely up to your
discretion if further steps should be taken and trust in your good judgement.

Signed,

Jelena Đureinović, University of Vienna;

Ivo Goldstein, Full Professor, Department of History, Faculty of Philosophy and Social Sciences,
University of Zagreb;
Stefan Gužvica, PhD Student, University of Regensburg;
Sanja Horvatinčić, Postdoctoral Researcher, Institute of Art History, Zagreb;
Goran Hutinec, Assistant Professor, Department of History, Faculty of Philosophy and Social
Sciences, University of Zagreb;
Tvrtko Jakovina, Full Professor, Department of History, Faculty of Philosophy and Social Sciences,
University of Zagreb;
Emil Kjerte, PhD Student, Clark University, Strassler Center for Holocaust and Genocide Studies;
Hrvoje Klasić, Assistant Professor, Department of History, Faculty of Philosophy and Social
Sciences, University of Zagreb;
Ljiljana Kolešnik, Institute of Art History, Zagreb, Croatia;
Lovro Kralj, PhD Student, Central European University;
Ognjen Kraus, president of the Jewish community Zagreb and the coordinator of the Jewish
communities in Croatia;
Ana Kršinić Lozica, PhD Student, Faculty of Humanities and Social Sciences, University of
Zagreb;
Todor Kuljić, Retired Professor, University of Belgrade, Faculty of Philosophy, Department of
Sociology;
Olga Manojlović-Pintar, Institute for Recent History of Serbia, Belgrade;
Nataša Mataušić, Museum Advisor, Croatian History Museum, President of the Administrative
Council of the Jasenovac Memorial Site;
Đorđe Mihovilović, curator, Jasenovac Memorial Site;
Bibijana Papo Hutinec, PhD Student, Faculty of Philosophy and Social Sciences, University of
Zagreb;
Ivo Pejaković, Director of the Jasenovac Memorial Site;
Vladimir Petrović, Core Curriculum Faculty, Boston University;
Milan Radanović, PhD Student, Department of History, Faculty of Philosophy and Social Sciences,
University of Zagreb/Researcher at the Archive of Serbs in Croatia;
Dr. Ljiljana Radonić, Privatdoz., Austrian Academy of Sciences;
Nenad Romić, Research Fellow, Coventry University;
Sanja Sekelj, Institute of Art History, Zagreb;
Kaja Širok, historian;
Aneta Vladimirov, Member of the Administrative Council of the Jasenovac Memorial Site; Head of
the Department of Culture of the Serbian National Council in Croatia;
Rory Yeomans, historian.