TESTIMONY OF ISLAT DIRECTOR LORI
B. ANDREWS, J.D.
TO FRENCH NATIONAL ASSEMBLY
NOVEMBER 26, 1999
I was recently interviewed by a German television reporter, who asked me how developments in genetics and reproductive technologies were going to challenge the ideals of the French revolution -- of liberty, equality, and fraternity. Genetic testing certainly has challenged ideas of liberty and equality -- increasingly, people in the United States are being denied insurance or jobs based on genetic prediction that they may develop a disease later in life. And fraternity in its most basic sense is challenged by the prospect of genetic enhancement and human cloning. Biologist Lee Silver foresees a future where the wealthy can afford to add genetic enhancements to their children and the poor cannot. Eventually, he thinks the two groups will diverge sufficiently that they will not be able to create children together. Humans, he predicts, will divide into two different species.
This is a vision that many Europeans reject. In Europe, there are more protections for people against genetic discrimination than in the United States. UNESCO’s Universal Declaration on the Human Genome and Human Rights, as well as the Council of Europe’s Convention on Human Rights and Biomedicine prohibit discrimination against people based on their genotypes.
The UNESCO document bans human cloning and the European Convention on Human Rights and Biomedicine forbids sex selection except for serious sex-linked diseases. The European Convention allows interventions on the human genome -- but only for preventive, diagnostic, or therapeutic purposes. Germ line gene therapy is prohibited because of concerns that it would produce individuals of "particular characteristics or required qualities."
Similarly, the 1994 French law, article 16-4, provides that no alteration may be made to genetic characteristics with a view to modifying a person’s lineal descent. In addition, under article 511-1, a 20 year penalty can be imposed on someone who "engages in a eugenics practice aimed at organizing the selection of persons."
The United States, with its frontier approach, generally rejects such regulations and prefers to rely on the free market to determine what scientific technologies are available for what purposes. Consequently, in the United States, couples can order "smart" sperm from a sperm bank with Nobel Prize winner donors, bid in an auction for attractive models’ eggs on the Internet, and use pre-natal sex selection to choose whether to bear a boy or a girl.
The practical lack of protections in this area in the United States is also, ironically, due to political pressure from pro-life groups who want to grant human embryos the same protections as adult human beings. The pro-life groups oppose any reproductive or genetic technologies involving embryos, including embryo stem cell research or human cloning because not all embryos in those processes survive.
Consequently, pro-life groups have prevented any federal research funds from being used for reproductive technologies. In addition, they have engineered the passage of a federal law that prohibits the creation of embryos for research purposes and prohibits research on embryos in which embryos are destroyed or put seriously at risk. Ironically, though, this eliminates the application of legal protections because our federal regulations protecting human subjects in research only apply if the research is federally-funded. Government-funded researchers are not allowed to undertake research which would destroy embryos. But privately-funded researchers may do so.
The pro-life sentiment in the United States has led to the anomalous situation that embryo stem cell research is being undertaken virtually exclusively by researchers with ties to for-profit biotech companies. For example, the Geron Corporation helped underwrite Dr. Gearhart’s work. Prices of Geron's stock rose 31 per cent after the researchers' announcements.1
In contrast, in France, the bans on embryo research apply whether public or private funds are used. Under French law, "a human embryo may not be conceived or used for commercial or industrial purposes."2 In addition, "all experimentation on embryos shall be prohibited."3
The contemporary debate in the United States challenging the ban on publicly-funded research which risks embryos may be instructive for our inquiry here today regarding whether France should permit embryo stem cell research.
As Dr. McLaren has indicated, embryo stem cells are primitive cells can grow into every type of body tissue, including nerves, bones, and muscles. It is speculated that these cells could even be coaxed to grow whole organs in the laboratory.
Three ways of obtaining stem cells have been documented. A University of Wisconsin group used excess embryos donated for research purposes by couples undergoing in vitro fertilization. The researchers allowed the embryos to divide for five days, and then cultured cells from the resulting mass before the cells could specialize into particular tissues or organs.
A second approach was used by Dr. Gearhart. He retrieved stem cells from the developing gonads of aborted embryos and fetuses. Then a group at the University of Massachusetts claimed that they had used a radically different procedure. A scientist had scraped off one of his cheeks cells and fused it with a cow egg from which the nucleus had been removed, creating a cloned human embryo which divided five times and appeared to create stem cells.
Many scientific issues will need to be faced before the cells’ therapeutic promise is met. Researchers have not yet figured out how to predictably make the cells grow into a particular type of tissue. And stem cells divide indefinitely, suggesting that they may be particularly susceptible to cancer.
Of more immediate importance than the scientific questions, though, are the profound moral and legal questions raised by the new stem-cell research. In the U.S., questions arose about the application of federal and state laws to the process, about payment for embryos, and about the appropriate oversight mechanism for such research.
Government attorneys in the United States noted that publicly-funded researchers could not remove stem cells from embryos -- this would be prohibited destructive embryo research. The attorneys stated, however, that government researchers could legally undertake research on stem cells that have already removed from embryos in the private sector.4
This has met with widespread opposition from the pro-life community, which argues that this interpretation violates the intent of our federal law. In addition, pro-life groups suggest that embryo stem cell research is unnecessary, given new research suggesting that alternative methods exist for repairing and regenerating human tissue. These involve using stem cells from bone marrow or even umbilical cord blood. Research in April 1999 suggests mesenchymal cells from bone marrow can be redirected to form fat, cartilage, and bone tissue.5 Other research indicates that cells from living nerve tissue or from adult cadavers can give rise to neural stem cells.
For the past year, our National Bioethics Advisory Commission has been deliberating about the proper regulation of embryo stem cell research. The Commission recently made its recommendations, suggesting that:
Derivation and use of stem cells from cadaveric fetal tissue and from excess in vitro embryos should be eligible for federal funding. (Using cadaver fetal tissue as Dr. John Gearhart did is already permitted.)
Embryos should not be created solely for research purposes though. And federal agencies should not fund research creating or using cells created through the cloning technique (somatic cell nuclear transfer into eggs).
The National Bioethics Advisory Commission made recommendations about the type of information that should be given to embryo donors. It also stated that donors should not be able to specify a particular patient to receive cells or other treatments created from the donor’s embryos. In addition, the National Bioethics Advisory Commission recommended a prohibition on the purchase or sale of embryos or cadaveric or fetal tissue.
This avenue of research was seen as sufficiently useful, yet problematic, that the National Bioethics Advisory Commission recommended the establishment of a National Stem Cell Oversight and Review Panel. These are just recommendations, though.
In the United States, the regulation of stem cell research is further complicated by the fact that our 50 states also have the opportunity to regulate research and those laws apply no matter what the source of funds, public or private. At the state level, statutes regulating (in fact, generally banning) embryo and fetal research will have an impact. Twenty-six of the 50 states have laws regulating research on the unborn.6 The laws vary enormously, with differing implications. For example, in 12 of those states, there is greater freedom to use a fetus for research if the fetus was not the subject of an abortion.7 But, since there are many practical difficulties to obtaining tissue from a miscarried fetus -- and there are medical reasons to believe such tissue may be less than optimal -- most stem cell research will not use miscarried conceptuses, but rather will use IVF embryos or will use aborted embryos or fetuses.
Nine states ban research on in vitro embryos altogether.8 These laws could create problems for researchers who want to culture stem cells from IVF embryos.9 The penalties are high -- in some states, the punishment includes imprisonment.10
Other states have restrictions on research involving fetuses which would affect researchers who culture stem cells by using gonadal tissue from dead aborted embryos or fetuses.11 In six states, if the aborted embryo or fetus is dead, the focus is primarily on assuring that the mother has given her consent.12 But in six other states, research on dead aborted conceptuses is severely restricted.13
In some instances, the woman or couple who donate an embryo or fetus for research purposes also face liability. While many state laws focus only on the use of the unborn in research, some additionally prohibit the transfer, distribution, or giving away of any live embryo for research purposes.14 In one state, a person who does so is subject to a fine of up to $5000 and up to five years’ imprisonment.15
Commercial practices involving embryos are also highly regulated. There is a federal ban on payment for fetal tissue in interstate commerce.16 Thirteen states ban payment for IVF embryos for research purposes.17 In addition, in 21 states, the organ transplant laws use language which is broad enough to forbid payment for fetal tissue which will be used in transplant or therapy.18
These bans on commercial practices are similar to the ban on payment for embryos in France. But they raise an important policy question: Is the ban on payment so broad that it will ban payment for the cells themselves, or even for the therapeutic products made out of the cells?
In France, there is an additional question, since French law does not allow profit-making organizations to process, store, distribute, or collect human tissue or cells.19
In the United States, while some state laws might prevent payment for embryonic cell lines, it is possible that if a cell line is new tissue produced from the genetic material of, but not originally a part of, the embryo, laws proscribing the sale of embryonic tissue may not apply. In fact, a Minnesota law prohibits the sale of living conceptuses or nonrenewable organs but does allow "the buying and selling of a cell culture line or lines taken from a non-living human conceptus. . . ."20 In contrast, Nevada’s broadly worded statute making it a crime for anyone to use or "make available . . . the remains of an aborted embryo or fetus for any commercial purpose" could conceivably outlaw the sale of cell lines from fetal tissue or even products made from those cell lines.21 Similarly, in Pennsylvania, no compensation or other consideration may be paid to any person or organization in connection with the procurement of fetal tissue or organs.22
If embryo stem cell research goes forward, greater attention needs to be paid to informed consent. Currently, couples undergoing in vitro fertilization are asked to choose among donation to another couple, termination, or research as the fate of their excess embryos. Such couples should be told specifically when their embryos will be used for stem cell research. Some couples, who might be comfortable with allowing their embryos to be used in research to improve fertilization techniques, may be troubled by an experiment that turns what could have been their potential child into a kidney, or a cell line that is for sale. The recipients of human tissue, too, should be told of its origins. Some people may not want treatment that uses cells derived from human embryos, just as some religious believers knows as Jehovah’s Witnesses will turn down treatments involving blood transfusions.
Those individuals who provide tissue -- whether embryos or cheek cells -- should be told whether it will be tested for infectious or genetic diseases, which could reveal personal information about the donors. What if, for example, cheek cells were used to make heart cells, which were found to have a genetic defect? That defect might make the donor unable to get medical insurance. Yet the institutional review board of the University of Massachusetts addressing the cheek cell research felt it was unnecessary to review the research, opining that self-experimentation does not require oversight.
With respect to human cloning, three of the 50 states have banned reproductive cloning -- the creation of children through the procedure. Even though, as I mentioned, nine states banned experimentation on embryos, those laws do not prohibit human cloning. The experimental cloning procedure -- injecting an adult’s DNA -- occurred with an egg. Once an embryo developed, nothing novel would be done. It would be inserted in a woman’s womb using the same technique as in standard in vitro fertilization.
At the national level, President Clinton issued an order forbidding the use of federal funds for human cloning, but that ban has little effect on private fertility clinics. For 20 years, the federal government has refused to provide funds for research on in vitro fertilization, but that hasn’t stopped the hundreds of privately financed IVF clinics from creating tens of thousands of babies. The President’s ban won’t stop scientists who wish to undertake cloning with private funds. The Raelians, a Swedish religious group, have offered such scientists private funds and laboratory space to begin their work.
Few laws exist in the United States to even prevent people from being cloned against their will. What if a wealthy man’s barber used DNA from hair follicles to create a clone -- and then sued the wealthy individual for child support? Under current law, people have little right to control their body tissue and genes once these materials leave their body. In Moore v. Regents of the University of California, a patient’s doctor, without his knowledge or consent, used the patient’s unique tissue to develop a cell line worth an estimated $3 billion dollars. The court found that the patient had no right to a share of the proceeds, which could lead to a snip-and-run industry of cloning from stolen bits of celebrity hair. (Already, one of our Nobel laureates, Kary Mullis, is marketing jewelry with celebrity DNA in it -- why not a human replica?)
Even if a wealthy individual like Bill Gates intended to clone himself, perhaps making Bill Gates 5.0, 5.1, 6.0, he might not be recognized by law as the legal parent. In some states, the legal parents would be Gates’ parents and the replicant would be his brother. In two other states, if the twin were gestated by a surrogate mother, the child would be considered the legal offspring of the surrogate and her husband, even though she had no genetic connection. Gates would be a legal stranger to the child.
Should human cloning be allowed? U.S. fertility clinics are currently observing a voluntary moratorium on human cloning because they suspect that success rates would be low, and because research on animals suggests the possibility of physical risks to any offspring in cloning attempts. As many as 25% of cloned animals die shortly before or shortly after birth.
Some of the cloning disasters suggest difficulties (such as "imprinting" problems) created by having just one genetic parent, and difficulties caused by using an older cell. Recently, it was announced that Dolly has cells closer in age to those of her progenitor than the 3-year-old sheep she is. This could lead to premature aging and early death.
Even if cloning posed no physical risks, the emotional impact could be devastating. If a cloned person’s genetic progenitor is a famous musician or athlete, parents may exert an improper amount of coercion to get the child to develop those talents. True, the same thing may happen -- to a lesser degree -- now, but the cloning scenario is more problematic. A parent might force a naturally-conceived child to practice the cello hours on end, but will probably give up eventually if the child seems uninterested or tone deaf. More fervent attempts to develop the child’s musical ability will occur if the parents chose (or even paid for) genetic material from a famous cellist. And pity the poor child who is the clone of a basketball star. If he breaks his kneecap at age ten, will his parents consider him worthless? Will he consider himself a failure?
And what if the original basketball player died next year of an inheritable cancer? In the United States, his young clones may be uninsurable because of their genetic makeups.
I believe that we will see human cloning in the United States in my lifetime. It is part of the American free market mentality, and the rising expectations about children. More and more children are being turned into consumer products.
American parents-to-be even want to give new genes to their offspring. In a Louis Harris poll sponsored by the March of Dimes, 42% of potential parents surveyed said they would use genetic engineering on their children to make them smarter; 43% to upgrade them physically. And there are great incentives for biotech companies to develop genetic enhancements. With four million births per year, and such a high parent interest, this is a bigger market than for Prozac or Viagra.
The situation in the United States is aggravated by the ability to patent genes. In France, the total or partial structure of a gene may not be the subject of a patent.23 When the Human Genome Project proposed to spend $3 billion of taxpayer money identifying all 80,000 to 140,000 human genes, most biological scientists in the United States had no expectation they would own the genes they studied.24 In fact, the idea at that time seemed absurd. Intellectual property law prohibits patenting a "product of nature."25 It also prohibits patenting a formula. Genes seem to be both.
Patenting genes has vastly changed the biological sciences. The commercial emphasis of life scientists is now ubiquitous. In the micro-electronics field, researchers left academia to form companies.26 In biology, however, researchers formed companies or joined boards without leaving their academic appointments. Consequently, physicians, patients, and policymakers relying on reported studies may not be able to discern which researchers have an improper profit motive in making positive reports. According to a 1996 study by Tufts professor Sheldon Krimsky, in 34% of 789 biomedical papers published by Massachusetts university scientists, at least one of the authors stood to make money from the results they were reporting.27 They either held a patent or were an officer or advisor of a biotech firm exploiting the research. None of the articles disclosed this financial interest.
Regardless of how a nation, its states, medical professionals, and individual biotechnology companies proceed, the questions raised by reproductive technologies, human cloning, and embryo stem cell research will only become more complicated as researchers make new discoveries. When the subject of research is the clay out of which humanity is shaped, decisions about its use affect us all.
FOOTNOTES
1. None of the three groups of researchers involved in the recent work with stem cells received federal funds for their research. A private biotechnology company, Advanced Cell Technology, supported Massachusetts’ work.
2. Art L. 152-7.
3. Art L. 152-8. There is an exception for studies done with the couple’s consent, for a medical objective, which are not harmful to the embryo. Such studies require an opinion from the Commission.
4. That opinion is not without controversy. As Douglas Johnson, legislative director for the National Right to Life Committee, told the Los Angeles Times, the NIH "may think it can protect itself by requiring that the embryos actually be killed by someone not receiving federal funds, or by requiring the federally funded researcher to clock out when he kills the embryos, but these would be subterfuges and do violence to the clear intent of the law."
5. http://www.bioethix.org/overview/statement.htm.
6. Ariz. Rev. Stat. Ann. §36-2302, -2303; Ark. Stat. Ann. §20-17-801, -802; Cal. Health & Safety Code §25956, 25957; Fla. Stat. Ann. §390.001(6), (7); 720 Ill. Comp. Stat. 510/12.1; Ind. Code Ann. §35-1-58.5-6; Ky. Rev. Stat. §436.026; La. Rev. Stat. Ann §9:121 et seq.; Me. Rev. Stat. Ann. tit. 22, §1593; Mass. Ann. Laws ch. 112, §12J; Mich. Comp. Laws Ann. §§333.2685, -2692; Minn. Stat. Ann. §145.421 to -.422; Mo. Ann. Stat. §188.037; Mont. Code Ann. §50-20-108(3); Neb. Rev. Stat. §§28-342 to -346; N.H. Rev. Stat. Ann. sec 168-b:15; N.M. Stat. Ann. §24-9A-1 et seq.; N.D. Cent. Code §14-02.02-01, -02; Ohio Rev. Code Ann. §2919.14; Okla. Stat. Ann. tit. 63, §1-735; 18 Pa. Cons. Stat. Ann. §3216; R.I. Gen. Laws §11-54-1; S.D. Codified Laws Ann. §34-23A-17; Tenn. Code Ann. §39-15-208; Utah Code Ann. §§76-7-310; and Wyo. Stat. §35-6-115.
7. This is because the other twelve of these laws apply only to research with fetuses prior or subsequent to an elective abortion. Ariz. Rev. Stat. Ann. §36-2302(A) (subsequent); Ark. Stat. Ann. §20-17-802 (subsequent); Cal. Health & Safety Code §123440 (subsequent); Fla. Stat. Ann. §390.0111(6) (prior or subsequent); Ind. Code Ann. §16-34-2-6 (subsequent); Ky. Rev. Stat. §436.026 (subsequent); Mo. Ann. Stat. §188.037 (prior or subsequent); Neb. Rev. Stat. §28-346 (subsequent); Ohio Rev. Code Ann. §2919.14(A) (subsequent); Okla. Stat. Ann. tit. 63, §1-735(A) (prior or subsequent); Tenn. Code Ann. §39-15-208 (subsequent); Wyo. Stat. Ann. §35-6-115 (subsequent).
8. Fla. Stat. Ann. § 390.0111(6); La. Rev. Stat. Ann. §9:121 et. seq.; Me. Rev. Stat. tit. 22 §1593; Mass. Ann. Laws. ch. 112 §12J; Mich. Comp. Laws. §§333.2685 to 2692; Minn. Stat. Ann. §145.421 (applies only until 265 days after fertilization); N.D. Cent. Code §§14-02.2-01 to -02; 18 Pa. Cons. Stat. Ann. §3216; R.I. Gen. Laws. §11-54-1. In Louisiana, an in vitro embryo may not be farmed or cultured for research purposes; the sole purpose for which an IVF embryo may be used is for human in utero implantations. La. Rev. Stat. Ann. § 9:122.
9. James A. Thomson, Joseph Itskovitz-Eldor, Sander S. Shapiro, Michelle A. Waknitz, Jennifer J. Swiergiel, Vivienne S. Marshall, and Jeffrey M. Jones, "Embryonic Stem Cell Lines Derived from Human Blastocysts," 282 Science 1145 (1998).
10. The Maine law, which applies both to research on embryos and research on fetuses, carries a maximum five year prison term. Me. Rev. Stat. tit. 22 § 1593. The Massachusetts and Michigan laws also carry with them a potential prison sentence of up to five years. Mass Ann. Laws 112 § 12J(a)(V); Mich. Comp. Laws § 333.2691.
11. Michael J. Shamblott, Joyce Axelman, Shunping Wang, Elizabeth M. Bugg, John W. Littlefield, Peter J. Donovan, Paul D. Blumenthal, George R. Huggins, and John D. Gearhart, "Derivation of Pluripotent Stem Cells from Cultured Human Primordial Germ Cells," 95 Proc. Nat’l Acad. Sci. 13726 (1998).
12. See, for example, Ark. Stat. Ann. § 20-17-802(2); Mass. Ann. Laws ch. 112 § 12J(a)(II); R.I. Gen. Laws § 11-54-1(d); Tenn. Code Ann. § 39-15-208(a). In Pennsylvania, the consent of the mother is required, and she must not receive any compensation (whether monetary or otherwise). Her consent is only valid once the decision to abort has been made. 18 Pa. Cons. Stat. Ann. § 3216(b)(1). In Michigan, the mother’s consent is required (Mich. Comp. Laws Ann. § 333.2687) but the state’s version of the Uniform Anatomical Gift Act must also be complied with. Mich. Comp. Laws Ann. § 333.10101 et seq.
13. Ariz. Rev. Stat. Ann. §36-2302, -2303; Ind. Code Ann. §16.34-2-6; N.D. Cent. Code §14-02.2-01 to -02; Ohio Rev. Code Ann. §2919.14; Okla. Stat. Ann. tit. 63, §1-735; S.D. Codified Laws Ann. §34-23A-17.
14. Me. Rev. Stat. Ann. tit. 22 § 1593; Mich. Comp. Laws Ann. § 333.2690; N.D. Cent. Code § 14-02.2-2(4); R.I. Gen. Laws § 11-54-1(f).
15. Me. Rev. Stat. Ann. tit. 22 § 1593. Michigan has a maximum five year prison term. Mich. Comp. Laws Ann. § 333.2691.
16. 42 U.S.C. 289g-2(a).
17. Fla. Stat. Ann. §873.05; Georgia Code Ann. §16-12-160(a) (except for health services education, id, at (b)(5)); 755 Ill. Comp. Stat. 50/8.1; La. Rev. Stat. Ann. §9:122; Me. Rev. Stat. Ann. tit. 22 §1593; Mass. Ann. Laws. ch. 112 §12(J)(a)(IV); Mich. Comp. Laws §333.2609; Minn. Stat. Ann. §145.422(3) (live); N.D. Cent. Code §14-02.2-02(4); 18 Pa. Cons. Stat. Ann. §3216(b)(3) (forbids payment for the procurement of fetal tissue or organs); R.I. Gen. Laws §11-54-1(f); Texas Penal Code §48.02; and Utah Code Ann. §76-7-311.
18. Ark. Code Ann. § 20-17-610(a); Cal. Health & S § 7155(a); Conn. Gen. Stat.§ 19a-280a; Haw. Rev. Stat. § 327-10(a); Idaho Code § 39-3411(1); 755 Ill. Comp. Stat. 50/8.1(a); Iowa Code § 142C.10(1); Minn. Stat. § 525.9219(a); Nev. Rev. Stat. § 451.590(1); N.H. Rev. Stat. Ann. § 291-A:11(I); N.M. Stat. Ann. § 24-6A-10(A); N.Y. Pub Health § 4307; N.D. Cent. Code § 23-06.2-10(1); Ohio Rev. Code Ann. § 2108.12(A); R.I. Gen. Laws § 23-18.6-10(a); S.D. Codified Laws § 34-26-55; Utah Code Ann. § 26-28-10(1); Vt. Stat. Ann. Health 18 § 5246(a); Va. Code Ann. § 32,1-289.1; Wash. Rev. Code § 68.50.610(1); W. Va. Code § 16-19-7a. Arizona’s laws apparently would not apply since they define a decedent to include a stillborn infant, but not a fetus. Ariz. Rev. Stat. § 36-849(1). Kentucky, though prohibiting the sale of "transplantable organs" (Ky. Rev. Stat. Ann. §311.171(1)), excludes "fetal parts or other tissues, hair, bones, blood, arteries, any products of the birth or conception . . . bodily fluids including sperm, ovum, ovaries, fetus [and] placenta" from its definition of "transplantable organ." Ky. Rev. Stat. Ann. § 311.165(5)(b).
19. AA L. 672-10.
20. Minn. Stat. Ann. § 145.422(3).
21. Nev. Rev. Stat. Ann. § 451.015.
22. 18 Pa. Cons. Stat. Ann. § 3216(b)(3).
23. Article L. 611-17.
24. In actuality, some scientists were quietly applying for gene patents, but it had not at that time reached public knowledge. Interview with Robert Cook-Deegan, May 13, 1999.
25. Funk Bros. Seed Co. v. Kalo Inoculant Co., 333 U.S. 127 (1948). The decision said, "patents cannot issue for the discovery of the phenomena of nature. The qualities of these bacteria, like the heat of the sun, electricity, or the qualities of metals, are part of the storehouse of knowledge of all men. They are manifestations of laws of nature, free to all men and reserved exclusively to none." Id. at 130 (citation omitted). However, if an inventor isolates and purifies a substance so that it could be used in a way the impure product could not, that inventor can receive a patent. In re Bergstrom, 427 F.2d 1394 (C.C.P.A. 1970).
26. Sheldon Krimsky, "The Profit of Scientific Discovery and its Normative Implications," 75 Chicago-Kent Law Review 15 (1999).
27. Sheldon Krimsky et al., "Financial Interests of Authors in Scientific Journals," 2 Science and Engineering Ethics 395 (1996). See also Vincent Kiernan, "Truth in No Longer Its Own Reward," New Scientist, March 1, 1997, at 11.