or COUNSEL 
SAN OP A e. HAMILTON 
BONNIE LOUNSBUPT* 
•ILLINOIS ANO MAINE ONLY 
LAW OFFICES 
EDWARD LEE ROGERS 
SUITE T-200 
17 1 S P STREET, N. W. 
WASHINGTON, D. C. 20036 
(202) 387-1600 
January 9, 1987 
Dr. James B. Wyngaarden 
Director 
National Institutes of Health 
Room 124 
SOOO Rockville Pike 
Bet’nesda, Maryland 20892 
Dr. William Gartland 
Director 
NIH Office of Recombinant Activities 
Building 31, Room 3B10 
National Institutes of Health 
Bethesda, Maryland 20892 
Dear Drs. Wyngaarden and Gartland: 
In response to your (Dr. Wyngaarden ' s) letter of December 
22, 1986, regarding the Wistar Institute's field testing of the 
recombinant rabies vaccine in Argentina, we have serious problems 
with your legal and factual analyses and disagree with your 
conclusions . 
Assuming, arguendo , the correctness of your interpretation 
of Section 1-C of the NIH Guidelines, as set out in your letter 
of December 22nd, the facts are not adequate to support the 
conclusion that Section 1-C was not violated here. 
The letter of December 5, 1986, frcm Dr. Koprowski, to which 
you refer, does not, of itself, provide any assurance that there 
was no NIH funding of the Argentina deliberate release. That 
letter states, in support of its conclusion that the field 
testing "was not supported by NIH funds," only that "[t]he funds 
were obtained from two private sources." An obvious question — 
not answered on the record — is whether the "two private 
sources" obtained their funding or any part thereof used in the 
experiment from NIH. Certainly, if NIH funds were used by such 
entities to support the Argentina testing, then there has been a 
violation of the Guidelines. Follow-up inquiries on thin issue 
Recombinant DNA Research, Volume 1 1 
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