DEPARTMENT OF MICROBIOLOGY 
THE MEDICAL COLLEGE OF WISCONSIN 
8701 WATERTOWN PLANK ROAD 
MILWAUKEE, WISCONSIN 53226 
Telephone (414) 257-8253 
Reply to: P.O. BOX 26509 
MILWAUKEE, WISCONSIN 53226 
December 27, 1979 
Dr. Donald S. Fredrickson 
Director, National Institutes of Health 
Bethesda, Maryland 20205 
Dear Dr. Fredrickson: 
I read with interest your proposed changes in the NIH Guidelines for 
Recombinant DNA research, as published in the November 30, 1979 issue 
of the Federal Register. I concur with your changes in all respects 
and have one suggestion which, although not necessary, might improve 
the wording slightly. My concern is that the term "eucaryotic protein" 
in section IV-D-l-c is perhaps not well defined, i. e., does it refer 
specifically to proteins encoded in the DNA of eucaryotic organisms 
and if so, are animal viruses and viroids considered to be eucaryotic 
organisms? 
Although somewhat more wordy, the last sentence in paragraph 1 of 
section IV-D-l-c might be changed to read as follows: "An exception, 
however, which does require prior review and approval by the IBC is any 
experiment in which there is a deliberate attempt to have the E. coli 
K-12 efficiently express as a protein product the information carried 
in any gene derived either from a eucaryotic organism or from any virus 
or viroid which infects a eucaryotic organism." 
This change, as underlined, is suggested solely for the pupose of 
calrifying what I interpret to be the full intent and meaning of the 
term"eucaryotic protein." 
Kent w. wiicox, rnu 
Assistant Professor 
[607] 
ESTABLISHED IN 1913 AS THE MARQUETTE UNIVERSITY SCHOOL OF MEDICINE 
