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The German Interior Ministry has said that the number of neo-Nazi websites based outside the country's legal jurisdiction has more than doubled this year.
Around 800 mostly German-language sites, broadcasting racist and Nazi propaganda, are taking advantage of the internet to get round German laws forbidding such material.
The frustration of the German authorities at their inability to prevent the broadcasts highlights an increasingly controversial debate about who controls content on the internet.
German law makes it a crime to disseminate Nazi propaganda or deny the Holocaust.
But how to extend that law into the borderless world of the internet?
Supreme Court
Last week Germany's Supreme Court ruled that someone outside the country posting Nazi material aimed at internet users inside Germany, could be prosecuted under German law.
 Mr Schily says many neo-Nazi sites are in the US |
Germany's Interior Minister, Otto Schily, says 90% of foreign-based neo-Nazi websites are set up in the United States, where they're protected by American freedom of speech laws.
The site's anonymous author could even be based in Germany.
He could simply transmit his material to a website which is physically located in America.
Identifying such individuals is extremely difficult.
France v Yahoo
Germany is not alone in trying to solve this problem.
Last month, a French court ruled that US-based website Yahoo must prevent French users from accessing auctions of Nazi memorabilia, which are unlawful in France.
On Thursday, though, Yahoo applied to an American court to rule that the French judgement was unenforceable.
Such attempts to impose national law on an inherently supra-national medium are clearly fraught with difficulty.
After all, as one observer put it, what happens if China wants to ban a human rights website based in France or Germany?
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