Apparent Discrepancies and Mischaracterisations in Imran Ahmed / CCDH Evidence to the UK Parliament Concerning the “Disinformation Dozen”

To: Media/Legal Counsel
From: Sayer Ji
Date: Nov. 16th, 2025
Re: Apparent Discrepancies and Mischaracterisations in Imran Ahmed / CCDH Evidence to the UK Parliament Concerning the “Disinformation Dozen”

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1. Purpose

This memo documents:

1. Apparent tensions and discrepancies between:

   • Oral evidence given by Imran Ahmed (CEO, Center for Countering Digital Hate, “CCDH”) to the Joint Committee on the Draft Online Safety Bill on 9 September 2021; and

   • Written evidence submitted by CCDH (OSB0009) to the same committee in September 2021, including the table expressly naming Sayer Ji as one of the “Disinformation Dozen.”

2. The way in which this evidence rhetorically and functionally casts named individuals as akin to terrorists, organised criminals, and sexual groomers, despite the absence of any criminal charge, trial, or finding.

3. The parliamentary and legal implications of giving potentially misleading or exaggerated evidence to a select committee, including the framework for contempt of Parliament.

This memo is intended as a standalone evidentiary and analytical document that can be linked or adapted in a Substack article or shared with legal and policy audiences.

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2. Key Sources

1. Oral evidence transcript

   • Joint Committee on the Draft Online Safety Bill, Corrected oral evidence: Draft Online Safety Bill, Thursday 9 September 2021, Evidence Session No. 1, Witness: Imran Ahmed.

   • Official PDF: https://committees.parliament.uk/oralevidence/2694/pdf/

2. YouTube recording of Ahmed’s oral evidence

   • “Online Safety Bill - CCDH’s CEO Imran Ahmed provides evidence to the UK Parliament.”

   • Video link:

1. Written evidence

   • CCDH written submission to the Joint Committee on the Draft Online Safety Bill: OSB0009 (Center for Countering Digital Hate).

   • URL: https://committees.parliament.uk/writtenevidence/38805/html/

2. Parliamentary / constitutional context

   • Clerk of the House of Commons, written evidence on Select committees and contempts, noting that giving false or misleading evidence to a select committee may constitute contempt of the House, even when evidence is not given on oath.

   • UK Parliament / Committee of Privileges material on select committee powers and contempts.

   • Background on parliamentary privilege and immunity for evidence (absolute privilege for written and oral evidence accepted by a committee; sanctions are therefore internal to Parliament rather than via civil/criminal courts).

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3. Background: How CCDH Presented the “Disinformation Dozen”

In its written evidence, CCDH tells the Joint Committee:

“CCDH’s research has shown that the ‘Disinformation Dozen’ – twelve anti-vaxxers who have built personal brands by spreading deadly vaccine disinformation – are responsible for up to 65 percent of deadly anti-vaccine disinformation on social media platforms.”

Immediately below, CCDH provides a table that explicitly names the twelve individuals, including “Sayer Ji”, and lists purported follower counts and platform reach.

In his oral evidence, Ahmed tells the Committee that CCDH’s report is:

“based on a concentration analysis… We found a nice statistic: 12 people produced two-thirds of the influence, of the shares. There is a bit of showmanship, a bit of theatricality, in picking 12 and two-thirds, but they are memorable.”

He goes on to describe these twelve people as “sophisticated bad actors” who together operate 97 accounts, and notes that Facebook’s Monika Bickert had described CCDH’s research as “nonsense”.

At the same time, Ahmed repeatedly frames the Disinformation Dozen as:

• A “super-spreader” node in a network of anti-vaccine extremism;

• Comparable to an organised crime network, a characterisation explicitly endorsed by a Committee member and accepted by Ahmed.

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4. Apparent Discrepancies and Tensions (Oral vs. Written)

4.1 The “65% / two-thirds” claim: statistic vs. theatre

• Written evidence presents CCDH’s conclusion as if it were a firm empirical finding:

“responsible for up to 65 percent of deadly anti-vaccine disinformation…”

• The language “CCDH’s research has shown” and the precise percentage (“up to 65 percent”) signal scientific authority and reliability to a legislative audience.

• Oral evidence, however, reveals that Ahmed himself views the “12 and two-thirds” framing as partly theatrical, not purely scientific:

“We found a nice statistic: 12 people produced two-thirds of the influence, of the shares. There is a bit of showmanship, a bit of theatricality, in picking 12 and two-thirds, but they are memorable.”

• He also concedes Facebook’s senior policy executive called CCDH’s methodology “nonsense,” acknowledging that major stakeholders question the validity of the 65% claim.

Implication:
To Parliament in writing, CCDH presents the 65% claim as a hard, quantitative result “shown” by their research. In oral testimony, Ahmed admits that the central headline statistic is constructed with “showmanship” and that a key counterparty (Facebook) regards their research as “nonsense.” This raises questions about how robust, transparent, and replicable the underlying method really is, and whether the written framing appropriately conveyed that uncertainty.

4.2 Scope: Population-scale responsibility vs. platform context

• The written submission implies that 12 individuals are responsible for the vast majority of deadly anti-vaccine disinformation online, without strongly qualifying that this is limited to a specific dataset, time window, or platform subset.

• In oral evidence, Ahmed acknowledges that:

  • There are “lots and lots of people who are spreading misinformation”;

  • CCDH’s 12-person focus is an exercise in concentration of influence, not a literal census of all disinformation;

  • The headline figure is crafted for rhetorical impact.

Implication:
The written evidence can easily be read as asserting that these twelve people, including Sayer Ji, are uniquelyresponsible for most “deadly” vaccine disinformation. Ahmed’s own oral remarks show this is, at minimum, a simplification bordering on overstatement, given his concessions that many others are involved and that the metric is an influence-concentration heuristic, not a direct measure of who is causing what share of global harm.

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5. Dehumanising and Criminalising Analogies

Ahmed’s oral evidence repeatedly places “anti-vaxxers” and, by implication, the named individuals in explicitly criminal and extremist frames:

1. Organised crime network

   • MP Darren Jones says: “To me this just sounds like an organised crime network.”

   • Ahmed does not correct or nuance this; he proceeds to answer on that basis, embedding the Disinformation Dozen within a “network” of bad actors that Parliament should disrupt.

2. Terrorism and death tolls

   • Ahmed tells the Committee:

“Think if the death toll from any terrorist group was in the hundreds of thousands… Anti-vaccination misinformation has taken lives—there are people who have died as a result of the misinformation they have been fed online…”

1. • This explicitly invites Parliament to think of “anti-vaccination misinformation” as equivalent in death toll to terrorist campaigns, and to consider criminal liability in that light.

2. Grooming and child sexual exploitation analogies

   • Later in the session, Ahmed states:

“…anti-vaxxers are like any type of groomer or recruiter… you can look at the way that AQ used to recruit or Hezbollah… or the way child sexual exploitation works. This is about making people not trust the authorities that they normally trust.”

1. • Here, “anti-vaxxers” are explicitly compared to:

     • Al-Qaeda and Hezbollah recruiters; and

     • Perpetrators of child sexual exploitation.

2. “Sophisticated bad actors” with financial motives

   • Ahmed describes the Disinformation Dozen as “sophisticated bad actors” who run a network of charities and LLCs that generate “millions of dollars of revenue.”

Implication for you personally:
Because CCDH’s written evidence names you directly in the Disinformation Dozen table, and Ahmed’s oral testimony then repeatedly compares “anti-vaxxers” to terrorists, organised criminals, and sexual groomers, a reasonable observer could understand Parliament to have been invited to view you personally as:

• A quasi-terroristic “super-spreader” whose speech is linked to “hundreds of thousands” of deaths;

• Part of an “organised crime network” of disinformation;

• Functionally comparable to groomers and extremist recruiters.

These frames are extraordinary given that you have not been convicted, charged, or even investigated as a criminal actor for your speech, and they go well beyond neutral policy analysis.

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6. Parliamentary & Legal Implications

1. Duty of accuracy & contempt of Parliament

   • The Clerk of the House’s memorandum on select committees and contempts states that giving false evidence or misleading a committee—whether by omission or commission—can amount to contempt of the House, even when evidence is not given on oath.

   • The Committee of Privileges has recognised that select committees may consider cases where witnesses “have failed to give truthful evidence,” and that admonishment or stronger measures may be appropriate.

2. Parliamentary privilege and limits on external legal redress

   • Written and oral evidence given to a select committee, once accepted, is protected by absolute parliamentary privilege; it cannot be used as the basis of civil or criminal proceedings in court.

   • This means that any remedy for misleading Parliament lies primarily within Parliament itself (e.g., complaints to the Committee of Privileges, political scrutiny), not through ordinary defamation or other civil litigation in respect of the evidence itself.

3. Potential issues raised by Ahmed / CCDH’s evidence

   This memo does not assert that Imran Ahmed knowingly set out to mislead Parliament; questions of intent would require further fact-finding. However, the documentary record supports at least the following concerns:

   1. Overstated certainty.
      The written claim that CCDH’s research has “shown” the Disinformation Dozen to be responsible for “up to 65 percent of deadly anti-vaccine disinformation” is presented to Parliament as a firm empirical finding. Yet in his oral evidence, Ahmed concedes that the “12 people / two-thirds of the shares” framing involved “a bit of showmanship, a bit of theatricality,” and acknowledges that Facebook’s policy head publicly dismissed CCDH’s analysis as “nonsense.”

   2. Compression of a complex landscape into a personalised enemies list.
      In writing, CCDH moves from “concentration of influence” on certain platforms to a much broader, largely unqualified statement that twelve named individuals are responsible for most “deadly” disinformation. That simplification obscures the wider information ecosystem and risks misleading legislators about the uniqueness and causal centrality of those individuals.

   3. Moral and quasi-criminal framing of named individuals.
      CCDH’s written evidence fixes those twelve names— including Sayer Ji—into the parliamentary record as a “Disinformation Dozen” responsible for “deadly” harms and subject to “enforcement progress.” Ahmed’s oral testimony then repeatedly invites Parliament to analogise “anti-vaxxers” to organised crime networks, terrorist actors with “hundreds of thousands” of deaths, and groomers involved in child sexual exploitation. In practical terms, this presents your lawful speech as morally and socially equivalent to criminal conduct, despite the absence of any criminal charge or judicial finding against you.

   Under the House’s own guidance, giving false or misleading evidence to a select committee may amount to a contempt of Parliament, whether or not the witness is under oath. Whether Ahmed’s and CCDH’s evidence crosses that threshold is a matter for Parliament, but the tensions outlined above are sufficiently serious to warrant scrutiny.

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READ MY LATEST REPORT ON THE IMPLICATIONS OF IMRAN AHMED’s 2021 Testimony to what is unfolding NOW….