by Alan Phillips, J.D.
February 18, 2011
It is not enough to be
informed about the many problems with current immunization policy
We must effectively apply that knowledge to expand our
right to make informed choices. Where the rubber meets the road with
vaccine rights is in the statutes and regulations that provide or
restrict those rights. Therefore, a great deal of my time is spent
helping citizens throughout the U.S. present their case to state
legislatures about the necessity of the right to make informed
choices wherever vaccines are concerned.
On February 10, 2011, citizens of New Hampshire met with a state
committee to present their case for the passage of a bill to provide
a conscientious exemption to immunizations. Most states east of the
Mississippi River offer only medical and religious exemptions;
Mississippi and West Virginia only medical.
By invitation and
request of an informed New Hampshire activist, I provided the
following information for them to present to the legislative
committee that is considering the bill. After having researched and
written this document, I am convinced that such a bill represents a
level of choice that is not merely justifiable, but rather, a moral
and ethical imperative.
The arguments are presented below. They are not comprehensive -
books have been written on some of these topics - but the goal with
legislatures is to make strong, concise arguments with credible
support. Their time is often limited, and their ability to hear
alternative points of view potentially limited as well.
is not so much "What is the whole truth?" as it is "What will get
the job done?"
The actual letter is
http://www.vaccinerights.com/legislativeprojects.html and revisions to the arguments may appear in the future on the
Vaccine Rights website as well.
ARGUMENTS FOR THE ENACTMENT OF A PHILOSOPHICAL EXEMPTION
I. Credit Given to Vaccines for 20th Century Childhood Infectious
Disease Declines is Misplaced
Childhood infectious disease decline throughout the 20th Century is
widely but erroneously attributed to vaccines.
On average, about 90
percent of infectious disease decline preceded vaccines, while some
diseases declined without any vaccines at all such as typhoid fever,
scarlet fever, scurvy and tuberculosis.1
In fact, some disease rates
actually increased following the introduction of vaccines. For
example, during 1962 U.S. Congressional hearings, Dr. Bernard
Greenberg, Biostatistics Department Head at the University of North
Carolina School of Public Health,2 testified that cases of polio
increased substantially after polio vaccines were introduced - 50
percent from 1957-58, and 80 percent from 1958-59 - and that the
Public Health Service deliberately manipulated statistics to give
the opposite impression.3
Meanwhile, polio declined in countries
that didn't vaccinate.4
Therefore, 20th century disease declines do
not support an absolute vaccine mandate.
II. A Reliable Vaccine-Disease Risk-Benefit Assessment is not
First, we do not have precise disease mortality data.
example, with regard to the recent H1N1 pandemic, the CDC reported
U.S. laboratory confirmed flu deaths (both swine and seasonal) for
the 2009-2010 flu season were 2,117.5
However, the CDC estimated
U.S. swine flu deaths alone at 8870 aa??" 18,300.6 In stark
contrast, Flu Tracker (Rhiza Labs) estimated only 4642 fatal U.S.
swine flu cases.7
Documenting disease deaths has been problematic
historically as well. For example, in 1974, the CDC determined that
there were 36 cases of measles in Georgia, while the Georgia State
Surveillance System reported 660 cases.8
The truth is, we have only
non-precise, widely varying "guesstimates" for disease mortality
We know even less about the scope and severity of vaccine injury
The Vaccine Adverse Event Reporting System (VAERS) and
National Vaccine Injury and Compensation Program (NVICP) have
revealed irrefutably that vaccines cause permanent injuries and
deaths, but they are inadequate measures of the scope of the
The FDA and CDC have admitted that reported adverse events
represent as few as 1-10% of the events actually occurring.9
According to former FDA Commissioner
David Kessler, reported events
may be less than 1 percent.10
there are huge unknowns concerning how vaccines affect other disease
rates, and when the actual number of vaccine injuries and deaths may
be up to 100 times greater than the number documented by the federal
government, state governments are ethically compelled to allow a
III. The Belief That Unvaccinated Persons Pose a Risk of Harm to
Others is Without Merit
If vaccines work, then of course unvaccinated persons pose no
risk to vaccinated persons at all.
The persistent, widespread claim
that unvaccinated people "put everyone else at risk" is, therefore,
nothing more than absurd fear mongering.
The likely real basis for
such claims is the enormous profit potential from vaccines. From the
perspective of the pharmaceutical industry, every man, woman and
child on the planet is a potential recipient of vaccines from the
moment of birth until their last breath.
industry, responding to this vast marketing opportunity, now has
over 330 vaccines either in development or already on the market,12
despite the profound drop in disease rates across the last century
suggesting the need for fewer, not more, vaccines.
have a conscientious exemption allowing them to opt out of this mad,
pharmaceutical feeding frenzy.
A more specific concern is the claim that the tiny percentage of
persons not vaccinated for medical reasons, perhaps along with the
larger percentage of vaccinated persons whose vaccines don't work,
are put at risk by those exercising non-medical reasons.
is also without merit. It is based on the herd immunity theory,
which states that if most of a population is immune, the entire
population is protected.
The presumed problem is that if too many
people opt out of vaccines, the herd immunity effect will be
compromised, and those not immune due to medical exemptions or
failed vaccines are at risk.
Aside from the absurd implication that unvaccinated persons somehow
become "disease magnets" that "create" or "attract" disease in
communities where diseases have been absent for decades (and whose
absence substantially preceded vaccines), this concern is erroneous
because the herd immunity theory has been substantially disproved.
For example, measles, mumps, small pox, pertussis, polio and Hib
outbreaks have all occurred in vaccinated populations.13,14,15,16,17
In 1989, the CDC reported:
"Among school-aged children, [measles]
outbreaks have occurred in schools with vaccination levels of
greater than 98 percent.18 [They] have occurred in all parts of the
country, including areas that had not reported measles for years."19
The CDC even reported a measles outbreak in a documented 100 percent
A study examining this phenomenon
"The apparent paradox is that as measles immunization
rates rise to high levels in a population, measles becomes a disease
of immunized persons."21
The disturbing implication here is that
efforts to maximize immunization rates may actually be
counterproductive. Recent outbreaks in California, New York and New
Jersey also occurred in highly vaccinated populations.22,23
Official statistics for the recent swine flu pandemic show that the
U.S. vaccinated 30 percent of the population against swine flu, yet
had more than eight times its proportional share of international
swine flu deaths. England vaccinated 8 percent of its population and
had two times its proportional share.
But Poland, which refused
swine flu vaccines altogether, had only one-tenth of its
proportional share of international swine flu deaths.24 These data
strongly suggest that the swine flu immunization campaigns may
actually have been counterproductive.
Therefore, citizens should
have the right, individually, to determine whether or not any given
vaccine is appropriate for themselves and their children.
IV. Mandatory Vaccination Prevents Citizens From Choosing Proven
Safer, Less Costly, More Effective Alternatives
In the fall of 2008, Cuba used homeoprophylaxis to protect 2.5
million residents of Cuba from a Leptospirosis outbreak following
The protective effect profoundly exceeded that of
conventional immunizations - 10 infections and no deaths with homeoprophylaxis vs. thousands of infections with many deaths in
prior years with conventional immunization. The cost was about
one-fifteenth that of conventional immunization.
This was achieved
"with full scientific verification."25
other instances of successful homeoprophylaxis have been documented
around the world over the past 200 years, including here in the
With homeoprophylaxis, adverse events are virtually
non-existent; there is none of the resulting death and disability
that inevitably occurs with the widespread use of conventional
immunizations. For those who consider homeopathy unproven or believe
that it can't work, the implications are even more dramatic.
is really the case, the use of immunizations in Cuba prior to 2008
was necessarily profoundly counterproductive.
A recent Japanese study found that "Vitamin D [is] better than
vaccines at preventing flu,"27 and experts say that vitamin D
toxicity fears are unwarranted.28
In a 2010 review, the esteemed
Cochrane Collaboration, an independent, international consortium of
medical researchers, issued a WARNING stating that "reliable
evidence on influenza vaccines is thin but there is evidence of
widespread manipulation of conclusions."29
The review found that
"vaccine use did not affect... working days lost" and "had no
effect on hospital admissions or complication rates."
legislators would do better to mandate vitamin D supplements than to
mandate flu vaccines.
Meanwhile, the documented manipulation of scientific data in flu
vaccine studies raises serious questions about the quality of
studies on other vaccines, if not also about the reliability of
medical research generally.
Indeed, according to Newsweek, the new
chief of Stanford University's Prevention Research Center says that
people are "being hurt and even dying" due to widespread errors in
It is no longer sufficient to base policy on
study conclusions alone. We must scrutinize the studies' methods,
data, funding sources, potential conflicts of interest, etc., before
accepting and acting on their conclusions.
Surely it is not the intent of state legislatures to implement
health policy based on erroneous information, or to prohibit
citizens from accessing the most efficacious, cost-effective, and
safest choices for disease prevention available.
questions concerning the reliability of vaccine medical research and
the availability of proven alternatives to conventional
immunizations compel state legislatures to provide citizens with the
right to a conscientious exemption from immunizations.
V. Conflicts of Interest Raise Serious Questions About Vaccine
The Advisory Committee for Immunization Practices (ACIP) develops
written immunization recommendations that are adopted by the CDC.
These become CDC recommendations that in turn are substantially
enacted into law by the states. However, some ACIP members have
conflicts of interest; some are right out of the vaccine industry or
otherwise situated such that they stand to profit from the very
policies they create.
Therefore, states must scrutinize ACIP
recommendations carefully, and accept or reject those
recommendations based on the findings of that scrutiny, and not
merely accept federal agency recommendations at face value.
There are conflicts of interest in the CDC as well. In December
of 2009, Julie Gerberding, M.D., M.P.H., announced her job change
from CDC Director (where she promoted vaccines) to President of
Given the revolving door between agency and
industry, we cannot presume that CDC recommendations are necessarily
Given this interrelationship between industry and
government, states have an ethical and moral imperative to exercise
careful scrutiny of CDC policies and recommendations, and to
implement state policy based upon the findings of their own
Conflicts of interest exist at the international level. On June
3, 2010, the British Medical Journal (BMJ) revealed the existence of
undisclosed, serious conflicts of interest in the WHO along with
scientifically unsupportable distortions of information from the WHO
concerning the swine flu pandemic.32
BMJ's Editor in Chief advised:
The WHO did not volunteer any
conflict of interest information until Aug. 11, 2010, after the
pandemic was declared to be over,34 and no one at the WHO resigned.
Given that conflicts of interest exist throughout federal and
international vaccine policy-making agencies, states are morally and
ethically compelled to scrutinize meticulously the recommendations
of those agencies, and to base state immunization policy and law on
the findings of their own, independent analyses.
Unless and until
that occurs, and unless such analyses clearly dictate otherwise,
states are morally and ethically obligated to provide citizens the
right to informed choice, by way of a conscientious exemption to
VI. Reliance on the Pharmaceutical Industry is Severely Misplaced
In December of 2009, the WHO reported:
Thus, a high level of scrutiny is required when considering
products, claims and recommendations coming from this industry.
The pharmaceutical industry regularly engages in criminal
behavior. In 2008, Merck was fined $650 million under the False
In 2009, Pfizer was assessed a $1 billion criminal fine,
along with a $1.3 billion civil fine, in its fourth settlement since
2002 over illegal marketing.
In 2009, Ely Lilly was assessed a $515
million criminal fine and a $900 million civil fine. In 2010,
GlaxoSmithKline was assessed a $150 million criminal fine and $750
million civil fine.
Over the past 10 years, these and other
Bristol Myers Squibb
...were assessed criminal and/or civil fines for
unlawful acts in the hundreds of millions of dollars.
pharmaceutical industry has become the biggest defrauder of the
federal government under the False Claims Act, and the problem has
gotten consistently worse over the past few years.36
It is critical to understand that criminal behavior, by definition,
means that the perpetrator had knowledge of the unlawfulness of the
These companies knew exactly what they were doing
each and every time. We can't know how many crimes were committed
that were not caught and prosecuted, but based on those that were,
we know that criminal behavior in the pharmaceutical industry is
routine, presumably because it is, on the whole, profitable (which
strongly suggests that there are crimes committed that don't get
caught - not unlike the drug cartels).
Since this behavior has
gotten worse in recent years, we know that it is substantially
likely to continue to occur in the future.
Given that the pattern of
behavior has been widespread and decades in the making, it is
absolutely fair - indeed, necessary - to factor this pattern of
behavior into an overall assessment of the character of this
industry, and to assess the general credibility and reliability of
their products accordingly.
The point is this:
NO ONE SHOULD EVER BE REQUIRED ABSOLUTELY TO TAKE
A PRODUCT FROM AN INDUSTRY THAT ROUTINELY ENGAGES IN CRIMINAL
Having the right to say 'NO' to the criminal pharmaceutical industry
is a moral and ethical imperative.
VII. Philosophical Exemptions Are Time-Tested and Safe
Currently, about 20 states containing a majority of U.S. citizens
have philosophical exemptions to immunizations.
If these exemption
rights were causing serious problems, these exemption laws would
either not have been enacted in the first place, or would have been
quickly repealed. However, this has not happened. Apparently,
philosophical exemptions have had no significant adverse effect on
infectious disease rates.
Furthermore, all states have authority under the U.S. Constitution
to mandate vaccines in the event of an emergency,37 regardless of
citizens' religious or philosophical objections, and to quarantine
unvaccinated persons when necessary.
So, if the unvaccinated should
ever prove to pose a serious risk of harm in the future, there is
authority for the state to act as it deems necessary to protect its
VIII. Medical Experts Disagree About Vaccine Safety and
There is a growing body of medical experts who are speaking out with
concerns about vaccines.38
Independent medical research contradicts
pro-vaccine research funded by the pharmaceutical industry. The
question, then, is whether or not government should assume the role
of deciding who is correct, and impose its opinion in a
one-size-fits-all policy on constituencies that consist of
individuals with varying needs.
The far better health care policy is
one where individuals have the flexibility to make a customized
risk-benefit analysis for themselves and their children in
consultation with their health care providers - professionals who
know their needs. Some may choose vaccines, but others may find that
for them, the risks outweigh the benefits.
Whatever the choice, all
should have the right to make that assessment without government
With herd immunity having been disproved, there is no
scientific basis for government imposing its will on the people,
collectively, usurping the rights of the individual.
IX. Vaccination Raises a Fundamental Rights Question
Government mandate of immunizations absolutely, without a
conscientious exemption, raises a profound fundamental rights
Vaccines carry a risk of permanent injury and death, and
that risk is presently neither quantifiable nor preventable.
society where the vast majority of disease decline preceded
vaccines, where in some instances vaccines caused a reversal of
prior disease declines, where in some instances vaccines have proven
to be counterproductive, where policy is based on a disproven herd
immunity theory, and where policy is substantially driven by a
corrupt industry that routinely engages in criminal behavior and
that profits handsomely by the policy it drives, such a mandate is
contrary to the very essence of what it means to be a democratic
The international debate about vaccine safety and effectiveness is
anything but resolved.
Indeed, a fair and open conversation is, if
ultimately inevitable, still yet to be fully had. Pending a final
outcome of this debate, and given the high stakes involved and
problems cited above, citizens in a free society should have the
right to decide for themselves what is in their own best interests.
Those who believe in vaccines are welcome to have them, and if
vaccines really work, they have nothing to fear from the
In the meantime, state governments have authority
under the U.S. Constitution to require unvaccinated children to stay
home during outbreaks, and to impose vaccines or quarantine on
unvaccinated citizens in declared emergencies. So, governments have
nothing to fear by granting their citizens the right to informed
Indeed, given the above, governments have nothing less than
a moral, ethical and legal imperative to provide that right.
Credit given to vaccines for 20th century infectious disease
declines is misplaced. Vaccine history does not support an absolute
mandate for vaccines.
Data for accurate vaccine-disease risk-benefit is not available.
Therefore, government lacks the means by which to adequately
determine whether or not vaccines provide a net benefit and are in
fact actually necessary, and therefore, must allow conscientious
Claims that the unvaccinated pose a risk of harm to the
vaccinated are unfounded (if vaccines work, how could an
unvaccinated person harm a vaccinated person?). Claims that the
unvaccinated pose a risk of harm to those who can't be vaccinated or
whose vaccines don't work are based on a misplaced belief in the
disproven "herd immunity" theory.
Therefore, the unwarranted,
fear-based concerns about risks posed by the unvaccinated do not
present a legitimate bar to the enactment of a conscientious
exemption right. Furthermore, those who can't be vaccinated or whose
vaccines don't work have viable alternatives that may work better
than vaccines and that are safer and less expensive.
The evidence shows that vaccines were actually counterproductive
in some instances. Clearly, then, government should allow a
conscientious exemption so that citizens can assess the merits of
There are viable, proven alternatives to immunizations. Homeoprophylaxis is far less expensive, more effective, and safer
with no risk of injury or death. Vaccines carry a risk of permanent
injury or death, are more costly, and are of questionable efficacy
when scrutinized objectively.
Therefore, citizens should have the
right to choose from among all of the available options. Absent this
option, government is endorsing only one of many legitimate health
care modalities, to the exclusive profit of one industry, thereby
substantially interfering with the free market.
Where conflicts of interest exist with those setting policy,
there is a moral and ethical imperative for citizens to have and
retain the right to evaluate and disagree with the resulting policy.
Immunization policy is driven by the very industry that manufactures
the vaccines, and that industry routinely engages in criminal
NO ONE SHOULD EVER BE REQUIRED TO USE PRODUCTS CREATED BY
AN INDUSTRY THAT ROUTINELY ENGAGES
IN CRIMINAL BEHAVIOR.
Conscientious exemptions are time-tested. About 20 states
representing a majority of the U.S. population currently have
philosophical exemptions. If these exemptions caused serious
problems, these exemption laws would have been repealed long ago.
Clearly, philosophical exemptions have not created serious health
problems, and if they ever should pose a problem, states retain the
authority to impose emergency vaccines and/or quarantines as needed.
A conscientious exemption poses no significant health threat to the
There is a growing body of lay persons and professionals,
including credible medical professional and researchers, who are
speaking out about problems with the conventional thinking on
immunizations. There is a valid vaccine controversy. Given this
reality, individuals should have and retain the right to make
Vaccines carry a risk of permanent injury and death. That risk
may vary substantially from individual to individual, and the
medical community has no gauge by which to assess that risk for
The herd immunity theory is flawed, so
individual citizens cannot be said to have a responsibility to
vaccinate for the sake of the community.
Therefore, by definition,
our democratic republic requires that citizens have the right to
decide for themselves, as individuals, whether or not vaccines are
right for them and their children.
In view of the above, and the scientific, legal, moral and ethical
imperatives presented and supported therein, we respectfully request
that the Honorable Senators and Representatives of this Great State
support and pass the Bill adding an exemption from immunizations for
1. For one of many sources, see Immunization Graphs at http://www.theoneclickgroup.co.uk/d...
2. Dr. Greenberg went on to become the Dean of the School of Public
Health at the University of North Carolina.
3. Hearings Before the Committee on Interstate and Foreign Commerce,
House of Representatives, 87th Congress, Second Session on H.R.
10541, May 1962, at 94.
4. The polio vaccine: a critical assessment of its arcane history,
efficacy, and long-term health-related consequences, section 7, Neil
Z. Miller, Thinktwice Global Vaccine Institute, http://www.thinktwice.com/Polio.pdf
5. 2009 H1N1 Flu U.S. Situation Update, May 28, 2010, CDC, http://www.cdc.gov/h1n1flu/updates/us/
6. CDC Estimates of 2009 H1N1 Cases and Related
Hospitalizations and Deaths from April 2009 through April 10,
2010, By Age Group, http://www.cdc.gov/h1n1flu/pdf/graph_April%202010N.pdf
7. Flu Tracker, Rhiza Labs, http://flutracker.rhizalabs.com/
8. Credited to Keith Block, M.D., Evanston, IL.
9. Testimony of Bernard Rimland, Ph.D., Before House Committee on
Government Reform, April 6, 2000, http://www.whale.to/v/rimland.html
10. Testimony of Barbara Loe Fisher, Co-Founder & President
National Vaccine Information Center, U.S. House Government
Reform Committee - August 3, 1999 "Vaccines: Finding a Balance
Between Public Safety and Personal Choice", http://www.whale.to/vaccines/fisher.html
11. Associating vaccines and subsequent diseases, Meryl Nass,
M.D., February 8, 2011, http://anthraxvaccine.blogspot.com/2011/02/this-blogger-fractured-her-right-arm.html
12. Pennsylvania Bio Issues Patient Impact Report on
Vaccines, More than 330 vaccines in development or on the market
to prevent life-threatening diseases, Business Wire, November 4,
13. Measles vaccine failures: lack of sustained measles specific
immunoglobulin G responses in revaccinated adolescents and young
adults. Department of Pediatrics, Georgetown University Medical
Center, Washington, DC 20007. Pediatric Infectious Disease Journal.
13(1):34-8, 1994 Jan.
14. Measles outbreak in 31 schools: risk factors for vaccine failure
and evaluation of a selective revaccination strategy. Department of
Preventive Medicine and Biostatistics, University of Toronto, Ont.
Canadian Medical Association Journal. 150(7):1093-8, 1994 Apr 1.
15. Haemophilus b disease after vaccination with Haemophilus b
polysaccharide or conjugate vaccine. Institution Division of
Bacterial Products, Center for Biologics Evaluation and Research,
Food and Drug Administration, Bethesda, Md 20892. American Journal
of Diseases of Children. 145(12):1379-82, 1991 Dec.
16. Sustained transmission of mumps in a highly vaccinated
population: assessment of primary vaccine failure and waning
vaccine-induced immunity. Division of Field Epidemiology, Centers
for Disease Control and Prevention, Atlanta, Georgia. Journal of
Infectious Diseases. 169(1):77-82, 1994 Jan. 1.
17. Secondary measles vaccine failure in health care workers exposed
to infected patients. Department of Pediatrics, Children's Hospital
of Philadelphia, PA 19104. Infection Control & Hospital
Epidemiology. 14(2):81-6, 1993 Feb.
18. MMWR (Morbidity and Mortality Weekly Report) 38 (8-9), 12/29/89.
19. MMWR "Measles." 1989; 38:329-330.
20. MMWR. 33(24),6/22/84.
21. Failure to reach the goal of measles elimination. Apparent
paradox of measles infections in immunized persons. Review article:
50 REFS. Dept. of Internal Medicine, Mayo Vaccine Research Group,
Mayo Clinic and Foundation, Rochester, MN. Archives of Internal
Medicine. 154(16):1815-20, 1994 Aug 22.
22. Update: Mumps Outbreak - New York, New Jersey, June 2009 -
January 2010, Morbidity and Mortality Weekly Report (MMWR), February
12, 2010 http://www.cdc.gov/mmwr/preview/mmwrhtml/mm5905a1.htm
23. Many whooping cough victims have been immunized; Experts
spar over prospects of new disease strain, Watchdog Institute,
December 13, 2010, http://www.watchdoginstitute.org/2010/12/13/whooping-cough-epidemic-california/
25. Successful Use of
Homeopathy In Over 2.5 Million People Reported From Cuba,
Official Homeopathy Resource, January 1, 2009, http://homeopathyresource.wordpress.com/2009/01/01/successful-use-of-homeopathy-in-over-5-million-people-reported-from-cuba/
26. Dana Ullman, Discovering Homeopathy, at 42 (Thomas L. Bradford,
Logic Figures, p68, 113-146; Coulter, Divided Legacy, Vol 3, p268)
27. Vitamin D better than vaccines at preventing flu, report
claims, The Sunday Times (U.K.), March 15, 2010, http://www.timesonline.co.uk/tol/news/uk/scotland/article7061778.ece;
American Journal of Clinical Nutrition (Am J Clin Nutr (March 10,
28. The Truth About
Vitamin D Toxicity, Vitamin D Council, http://www.vitamindcouncil.org/vitaminDToxicity.shtml
29. Vaccines for preventing influenza in healthy adults,
30. Why Almost Everything You Hear About Medicine Is Wrong, Sharon
Begley, Newsweek.com, January 24, 2011, http://www.cdc.gov/mmwr/preview/mmwrhtml/mm5905a1.htm
31. Dr. Julie Gerberding Named President of Merck Vaccines,
Merck Newsroom, December 21, 2009, http://www.merck.com/newsroom/news-release-archive/corporate/2009_1221.html
32. Conflicts of Interest: WHO and the pandemic flu "conspiracies",
BMJ, June 3, 2010, http://www.bmj.com/cgi/content/full/340/jun03_4/c2912
33. Excerpts of remarks by Fiona Godlee, Editor-in-Chief of the
British Medical Journal, during an exchange of views in Paris with
PACE's Health Committee on the handling of the H1N1 pandemic, 4 June
34. WHO Identifies Conflicted Pandemic Panel Members, Pharmalot,
August 11, 2010, http://www.pharmalot.com/2010/08/who-identifies-conflicted-pandemic-panel-members/
35. Medicines: corruption and pharmaceuticals, World Health
Organization Website, Fact Sheet No. 335, December, 2009,
36. Public Citizen Study:Pharmaceutical Indusry Is Biggest
Defrauder of the Federal Government Under the False Claims Act,
37. Jacobson v. Mass., 197 U.S. 11 (1905)
38. See, e.g., the International Medical Council on Vaccination at
http://www.vaccinationcouncil.org, and The Pandemic Response