with respect to making grants-in-aid for cancer rcseai'ch 
using recombinant DMA techniques, and with respect to the 
adoption of the Recombinant DM Research Guidelines for 
cancer research using recombinant DMA techniques. 
95* The funding of recombinant DMA research and promulga- 
tion of Recombinant DMA Research Guidelines by defendants in 
disregard of the procedural requirements of subsections (c) and 
(h) of Section 301 of the Public Health Service Act is ultra 
vires and illegal. 
96. The failure of defendants to comply with the procedural 
requirements of the Public Health Service Act render the funding 
of grants for recombinant DMA research and the promulgation of 
the Recombinant DMA Research Guidelines invalid and without 
force or effect. 
97. Despite the illegality of defendants’ actions in 
funding grants for recombinant DMA research and in promulgating 
the said Guidelines, the defendants continue to fund such grants 
and have implemented and applied said Guidelines as though they 
had full force and effect. 
98. The illegal actions of defendants in failing to comply 
with the requirements of the Public Health Service Act adversely 
affects the rights and interests of the plaintiff. 
99. The plaintiff is without adequate remedy at law. 
34 
[B-36] 
