The Holodomor and the Turks' mass murder of Armenians were not the Holocaust. But Raphael Lemkin nevertheless called them both genocides. That not all genocides rise to the level of the Shoah does not mean they're not genocides. Lemkin never defined the Shoah as a legal benchmark for defining genocide as the "elimination, in whole or in part, of a people". His benchmark was intention to eliminate a people, which Russia has clearly shown in the catalogue of eliminationist rhetoric on justsecurity.org, which you repeatedly refuse to read or acknowledge. Add the non-military components of Russia's war, which your quote ignored:

* Banning the Ukrainian language and propagating the genocidal myth that Russians and Ukrainians are one people.

* Forced mass deportations and kidnapping and forced adoptions of children,

* Demolishing monuments to the Holodomor, an integral part of Ukrainian cultural identity.

* Systematic looting of Ukrainian art treasures

and the genocidal intention picture is complete. Lemkin would demolish your view as genocide denial.

Stick to customer service. You're not a competent lawyer. A competent lawyer would never build an argument around a phony straw man so easily knocked down.