Comments on the Proposed Revision 
of the Guidelines for Recombinant DNA Research 
We respectfully offer the following comments, both general end 
specific, on the proposed revision of the guidelines: 
A . General. 
The NIH Guidelines for Recombln.int DNA Research as presently 
constituted do not apply to research in this area conducted in 
private industrial laboratories; nevertheless, the spirit and intent 
of the guidelines has been and will continue to be followed by these 
groups. If, at some time in the future, complete adherence to the 
guidelines becomes mandatory for all laboratories involved in 
recombinant DNA research certain procedures in the guidelines pose 
a difficult problem in terms of patentability of new concepts and 
protection of proprietary interests. With the few exceptions dis- 
cussed in later specific comments, compliance with all other features 
of the guidelines appears reasonable. 
We wish to emphasize, however, that we also have great concern 
for the lack, of protection afforded information developed through 
academic, government-funded research. To be in the public interest, 
more is required of government -funded research than the investigation, 
development and refinement of recombinant DNA techniques for producing, 
say. Insulin or pituitary hormone by these means. The public interest 
is served in part when the research from academic institutions is 
subjected to' the investigation, development, and refinement 
[Appendix A — 38] 
