The Complaint alleges that TUI A.G., Karl Kolb GmbH, and Heberger Bau A.G. made money off this genocide.

The Complaint was filed in the Civil District Court for the Governorate of Halabja, Kurdish Region of Iraq and alleges that these companies played a central role in a conspiracy to profit from enabling and assisting Saddam Hussein to carry out attacks that were later described as genocide and represented the highest concentration of lethal substances ever used against a civilian population.  The District Court of Halabja has jurisdiction to rule on these lawsuits.  The victims may file ancillary actions in London against the companies whose shares are traded on the London stock exchange, if the Complaint succeeds. 


The Complaint draws on recently uncovered evidence and testimony from experts hired by the German Export Authority.  This evidence, the complaint alleges, indicates that these German companies, along with other co-conspirators, knowingly entered into the conspiracy with the Saddam regime and profited from:

  • building the chemical weapons plants and gas chambers required for weapons development, concealing their real purpose;

  • providing chemical weapons precursors, components and equipment;

  • helping the regime to bypass international restrictions meant to limit its chemical weapons program after being confronted with evidence the regime was actively using those illegal weapons.

We say that prior to the conspiracy, the Saddam Regime did not possess chemical weapons, and it lacked the capability to develop such unlawful weapons and that without these company’s chemical precursors, technological prowess, complicity in hiding the weapons program, and funding, Saddam’s regime would never have been able to develop the chemical weapons or pull off the highest concentration of lethal substances ever used against a civilian population. 

The depths of this alleged conspiracy and lack of any moral red lines is unnerving, with German companies even building human-sized gas chambers (which they called "inhalation chambers") for Saddam to test these chemical agents on mammals and allegedly on prisoners of war. 

To read a more complete list of the actions we say these companies took to hide and develop this chemical weapons program for Saddam Hussein, click here