funded by Mill is being performed at Columbia University, New York 
University, Yeshiva University and Rockefeller University. The 
members of Friends of the Earth who reside in New York City and 
elsewhere are and will be adversely affected and aggrieved by 
the dangers to their hca3.th and the potential disruption of 
their use and enjoyment of natural resources, which could result 
I 
j from organisms produced in recombinant DMA research. 
I 4. Defendant Joseph A. Califo.no, Jr., is Secretary of the 
j 
jj Department of Health, Education, and Welfare of the United States. 
i| 
[I Defendant James F. Dickson III, M.D. is Assistant Secretary for 
j Health of the Department of Health, Education, and Welfare of 
J the United States. Defendant Dr. Donald S. Fredrickson is 
1 Director of the National Institutes of Health of the Department 
I 
| of Health, Education, and Welfare of the United States. The 
'j National Institutes of Health (NIH) is the federal agency 
jj authorized to fund and regulate biomedical research under the 
i 
j Public Health Service Act. 
III. AS AND FOR PLAINTIFF'S FIRST CLAIM 
j A. RECOMBINANT. DNA RESEARCH. 
| 5* By or about 1973 a scientific technique was developed 
l 
j which enables scientists t.o propagate novel living organisms 
! by combining the hereditary substance, DNA, from unrelated 
jj organisms. This technique has been variously termed recombinant 
ji 
DNA research, gene splicing, gene stitching, molecular cloning, 
'i 
j and genetic manipulation, among others, 
i 
> 6. DNA, or deoxyribonucleic acid, is the chemical substance 
j which makes up the genes and chromosomes of living organisms. 
It contains the code or set of instructions which guides the 
development, maintenance and reproduction of organisms and 
determines their form. 
I 
4 
[B— 6 ] 
