leaving the courthouse, amicus curiae is pleased with the 
opportunity to present this additional information to the Court. 
Respectfully submitted, 
William I. Althen 
Kilcullen, Smith & Heenan 
1800 "M" Street, N.W. 
Suite 600N 
Washington, D.C. 20036 
Tel. (202) 296-5700 
Attorney for Amicus Curiae 
American Society for Microbiology 
CERTIFICATE OF SERVICE 
I hereby certify that a copy of the foregoing Supplemental 
Memorandum was mailed by first class mail, postage prepaid, this 
19th. day of January 1978 to Ferdinand Mack, Esquire, Senate 106, 
17 West Jefferson Street, Rockville, Maryland 20850, Attorney for 
Plaintiff, and Mark Wine, Esquire, Room 2136, Land and Natural 
Resources Division, Department of Justice, Washington, D.C. , 
Attorney for Defendants. 
William I. Althen 
[Appendix C — 180] 
