Dear Board Members,

I assert that the present practice of marketing of vaccinations by Veterinarians for companion animals without informed consent and where there is no benefit to the pet constitutes fraud by misrepresentation, fraud by silence, theft by deception, and undue influence. I allege this is a common practice on the part of over 90% of Veterinarians engaged in companion animal practice in this state. 

I hereby file a complaint about the fraudulent marketing practices by Veterinarians in the State of Texas for violation of the Texas Penal Code and the Rules of Professional Conduct, Rule 573.26 which states: Licensed veterinarians shall conduct their practice with honesty, integrity, and fair dealing to clients in time and services rendered, and in the amount charged for services, facilities, appliances and drugs.

               I.      Recommending, administering, and charging for Canine Corona virus vaccinations
for adult dogs is fraud by misrepresentation, fraud by
silence, theft by deception, and undue influence given
the literature that states:

1.                   Dogs over eight weeks of age are not susceptible to canine corona virus disease.Canine corona virus has never been demonstrated to cause disease in adult dogs. 

2.                 The argument that dogs that develop parvovirus
          enteritis concurrently with corona virus infection will
          develop worse symptoms than a dog that develops
          parvovirus alone is without merit. If dogs over eight
          weeks of age are immunized against canine
          parvovirus they will not develop symptoms of canine
          corona virus disease. Addition of an unnecessary
          antigen to the vaccine will result in increased risk of
          adverse reactions.

        3.                   Immunologists doubt that Canine Corona virus
          vaccine works, as it would require secretory mucosal
          IgA antibodies to protect against corona virus
          infection, and a parenteral vaccine does not
          accomplish this very well.

4.        The American Animal Hospital Association, the
           American Veterinary Medical Association Council on
           Biologic and Therapeutic Agents and Twenty-two
           Schools of Veterinary Medicine including Texas A&M
           University do not recommend canine corona virus
           vaccine.

5.       Gastroenterologists at Schools of Veterinary Medicine including Dr Michael Willard at Texas A&M University have stated that they have only seen one case of corona virus disease in a dog in ten years.

6.       On at least one occasion large numbers of dogs have died from adverse reactions to corona virus vaccine.

7.       A reasonable client would not elect corona virus vaccination for an adult dog if
 presented this information.

References:

        Dogs over 8 weeks of age do not develop disease from canine corona virus.

1.       Wolf, Alice M., Vaccinations-what’s right? What’s not? Compendium on CE,
Schering-Plough Animal Health, 1999, pg. 32,33.

2.  Paul, Michael A., Vaccinations-what’s right? What’s
     not? Compendium on CE,Schering-Plough Animal
     Health, 1999, pg. 32,33.

3.  Schultz, Ronald D., “Are we vaccinating too much?”
     JAVMA, No. 4, August 15, 1995, pg. 421.
   

4.  Schultz, Ronald D., “Current and future canine and
     feline vaccination programs”, Veterinary Medicine,
     March 1998, pg. 251.

5.   Klingborg, Hustead, Curry Galvan, AVMA Council On
      Biologic and Therapeutic Agent’s report on cat and
      dog vaccines, JAVMA, Vol 221, No 10, Nov 15, 2002.

6.    Paul, Michael, Report of the American Animal
      Hospital Association Canine Vaccine Task Force:
      2003 Canine Vaccine Guidelines, Recommendations,
      and Supporting Literature, AAHA Foundation, March
      2003

7.   Ford, Richard B, Vaccines and Vaccinations, The
     Veterinary Clinics of North America, Volume 31, No 3,
     May 2001  

8.   Wilson RB, Holladay JA, Cave JS, A Neurologic
      Syndrome Associated with the Use of Canine
      Coronavirus-Parvovirus Vaccine in Dogs, compendium
      on CE, 8,1986, 117-124.

     II.       Recommending, administering, and charging for re-
                  administration of modified live vaccines like Canine
                  Distemper, Canine Parvovirus, Feline 
                  Panleukopenia, injectable Feline Rhinotracheitis,
                 and injectable Feline Calicivirus on an semi-annual,
                 annual, or bi-annual basis is theft by deception,
                  fraud by misrepresentation, misrepresentation by
                  silence, and undue influence given the literature
                   that states:

1.       The American Veterinary Medical Association, Council on Biologic and Therapeutic Agents has advised the USDA Center for Veterinary Biologics that there is no scientific data to support label claims for annual re-administration of modified live vaccines, and label claims should be backed by scientific data.

2.       It is the consensus of immunologist that a modified live virus vaccine must replicate in order to stimulate the immune system. With repeat administration of a MLV vaccine antibodies from a previous vaccination will block the replication of the new vaccinate virus. The immune status of the patient is not enhanced in any way. There is no benefit to the patient. The client is paying for something with insignificant or no effect, except that the patient is being exposed to unnecessary risk of an adverse reaction.

3.       A temporal association has been demonstrated between vaccinations and the development of Immune Mediated Hemolytic Anemia.

          4.       It has been demonstrated that the duration of
                    immunity for Canine Distemper virus is 7 years by
                    challenge, and 15 years by serology; for Canine
                    Parvovirus is 7 years by challenge, for Feline
                    Panleukopenia, Rhinotracheitis, and Feline Calicivirus
                    is 7.5 years by challenge.

References:

1.    HogenenEsch Harm, Dunham Anisa D, Scott-Moncrieff Catharine, Glickman Larry, DeBoer Douglas J, Effect of vaccination on serum concentrations of total   and  antigen-specific immunoglobulin E in dogs, AJVR, Vol 63, No. 4, April 2002, pgs. 611-616.

2.    Wolf, Alice M., Vaccinations-What’s right? What’s not? Compendium on  Continuing Education, Schering-Plough Animal Health, 1999, pg. 32.

3.    Wolf Alice, Vaccines of the Present and Future, Proceedings of the World Animal Veterinary Congress, Vancouver 2001.

4.    Schultz, Ronald D., “Are we vaccinating too much?” JAVMA, No. 4, August 15,
1995, pg. 421.

5.    Schultz, Ronald D., “Current and future canine and feline vaccination programs”, Veterinary Medicine, March 1998, pg. 243.

6.  Schultz, Ronald D, Duration of Immunity to Canine Vaccines: What We Know and What We Don’t Know, Proceedings – Canine Infectious Diseases: From Clinics to Molecular Pathogenesis, Ithaca, NY, 1999, 22.

          7.  Schultz, Ronald D, The Vaccine Controversy: What Vaccines Do
               Cats and Dogs Really Need and How Often Do They Need To Be
               Vaccinated? Department of Pathobiological Sciences, School of
               Veterinary Medicine, University of Wisconsin-Madison.

8.      Larson L J, Sawchuck S, Bonds M D, Schultz RD, Comparison of Antibody Titers Among Dogs Vaccinated, One, Two, Three Years Previously, Proceedings of 80^th
Meeting of the Conference of Research Workers in Animal Diseases, CRWD,
Chicago, IL, 1999.

9.    Gorham, J.R., “Duration of vaccination immunity and the influence on subsequent  prophylaxis” JAVMA 149:699-704; 1966

10.    Phillips, Tom R. and Schultz, Ronald D, “Canine and Feline 
  Vaccines”, Current Veterinary Therapy XI, ed. Kirk and
  Bonagura, pg. 202, 205, WB Saunders Co, Philadelphia, PA
  1992.

11.      Klingborg Donald, Principles of Vaccination, AVMA Council on
        Biologic and Therapeutic Agents, Policy on Biologics, April 2002

12.    Paul, Michael, Report of the American Animal Hospital
        Association Canine Vaccine Task Force: 2003 Canine Vaccine
        Guidelines, Recommendations, and Supporting Literature, AAHA
        Foundation, March 2003

          13.   Ford, Richard B, Vaccines and Vaccinations, The Veterinary
                 Clinics of North America, Volume 31, No 3, May 2001

14.   Tizard Ian, Use of serologic testing to assess immune status of
       companion animals, JAVMA,Vol 213, No 1, July 1, 1998.

 15.  Scott FW, Cordell MG, Long – term immunity in cats vaccinated
       with an inactivated trivalent vaccine, AJVR, May 1999, Vol. 60,
       No. 5.

 16.  Lappin MR, Andrews J, Simpson D, Jensen W, Use of Serologic
       Tests to Predict Resistance to Feline Herpesvirus 1, Feline
       Calcivirus, and Feline Parvovirus Infection in Cats, JAVMA,
       220[1]: 38-42 Jan 1,2002

III. Ordinances by Counties and Municipalities requiring annual rabies vaccination are illegal, as they require the client to purchase something with no effect. The recommendation of annual rabies vaccination for dogs and cats with three- year duration of immunity vaccine is theft by deception, fraud by misrepresentation, misrepresentation by silence, and undue influence given that:

1.                   Rabies vaccine has been licensed by the USDA as a three- year vaccine. Rabies vaccine has been proven to have a minimum duration of immunity of three years by challenge to the USDA, seven years by serology by Dr Ron Schultz, and 4 years for cats and 5 years for dogs by challenge by Aubert.

2.                   Beyond the second vaccination, no data exist to demonstrate that the immune status of the pet is enhanced. Data shows that the immune status of the pet is not enhanced. When the rabies vaccine is re-administration the client is paying for something with no benefit.

3.                   The National Association of State Public Health Veterinarians recommendation is for vaccination of dogs and cats for rabies at four months, one year later, and then every three years subsequently. This recommendation has been proven effective in 33 States in the United States.

                4.              The Texas Department of Public Health has adopted a new
                    tri-annual policy effective in March 2003.

References:

1.   The Texas Department of Public Health, White Paper on Options for rabies
vaccinations.

2.    HogenenEsch Harm, Dunham Anisa D, Scott-Moncrieff Catharine, Glickman Larry, DeBoer Douglas J, Effect of vaccination on serum concentrations of total and antigen-specific immunoglobulin E in dogs, AJVR, Vol. 63, No. 4, April 2002, pg 611-616.

3.     Wolf, Alice M., Vaccinations-What’s right? What’s not? Compendium on Continuing Education, Schering-Plough Animal Health, 1999, pg. 32.

4.   Wolf Alice, Vaccines of the Present and Future, Proceedings of the World Animal Veterinary Congress, Vancouver 2001.

5.    Schultz, Ronald D, Duration of Immunity to Canine Vaccines:
     What We Know and What We Don’t Know, Proceedings – Canine
     Infectious Diseases: From Clinics to Molecular Pathogenesis,
     Ithaca, NY, 1999, 22.

6.     Aubert Michel F, The practical significance of rabies antibodies
      in cats and dogs, Scientific and Technical Revue, 11(3) 735,
     1992 Paris, France

7.       “Administration of rabies virus vaccines to cats is subject
       to inconsistent state and local statutes. In some cases, the
       requirements fail to consider the duration of protection
       such vaccines induce; annual administration of rabies
       vaccines approved for triennial administration is required in
       many locals. Veterinary organizations should continue to
       work with state and local governing bodies to ensure that
       rabies virus vaccine regulations are consistent with the
       known duration of immunity of available vaccines.”
     Richards J, 2000 Report of the American Association of Feline
     Practitioners and the Academy of Feline Medicine Advisory Panel
     on Feline Vaccines.

8.       “Local and regional regulatory authorities mandate
            revaccination schedules including some that are more
            frequent than necessary as demonstrated by scientific
           evidence.”
           Klingborg, Hustead, Curry Galvan, AVMA Council On Biologic and
        Therapeutic Agent’s report on cat and dog vaccines, JAVMA,Vol
        221, No 10, Nov 15, 2002.

9.     “Every effort should be made to change laws that require
         vaccination with this rabies product more often than every
         three years since annual vaccinations cannot be shown to
         increase efficacy and it is known to increase adverse events”
         Paul, Michael, Report of the American Animal Hospital Association
       Canine Vaccine Task Force: 2003 Canine Vaccine Guidelines,
       Recommendations, and Supporting Literature, AAHA Foundation,
       March 2003

IV. The recommendation for administration of Leptospirosis
      vaccination in Texas without informed consent of the
      incidence in the locality and the potential side effects is theft
      by deception, fraud by misrepresentation, misrepresentation
      by silence and undue influence given the fact that:

1.            Although Leptospirosis is re-emerging as an endemic disease for dogs in some areas of the country, Leptospirosis in dogs in Texas is a very rare disease. According to the Texas Veterinary Medical Diagnostic Lab there are only an average of twelve cases of Leptospirosis documented in dogs in Texas per year. Factors to identify those dogs that are at risk have not been identified. Given that there are over 6 million dogs in Texas, the risk of leptospirosis disease to a dog is less than 2 in a million.

2.           The commonly used vaccine only contains serovars Lepto. canicola, and Lepto. icterohaemorrhagiae, and no cross protection is provided against the other three serovars diagnosed in Texas. Newer vaccines containing Lepto pomona, and Lepto grippotyphosa are available. To provide protection for a dog against Leptospirosis would require two vaccines with four serovars annually.

3.            Although humans can develop Leptospirosis, the spread of Lepto. from a dog to a human has never been documented and is thought to be a very low risk.

4.       Given that the risk of an adverse reaction, a reasonable client would not elect vaccination of their pet for leptospirosis if provided with the above information.

References:

1.    Angulo, A. B. DVM, MS, PhD, ACVM, College Station, Texas, Personal phone conferences. (Antec samples are all sent to the TVMDL, Idexx samples are sent to Michigan and Texas results are not available.)

2.    Klingborg, DJ, Hustead DR, Curry-Galvin E, AVMA Council on Biologic and Therapeutic Agents’ Report on cat and dog vaccines, JAVMA, Vol. 221, No 10, Nov 15, 2002, pg 1401- 1407.

              3.   Wolf Alice, Vaccines of the Present and Future, Proceedings of
                    the World Animal Veterinary Congress, Vancouver 2001

V.     The recommendation of Lyme disease vaccine for dogs residing
      in Texas without informed consent is fraud by
      misrepresentation, misrepresentation by silence and undue
      influence given the literature that states:

 1. Eighty per cent of Lyme disease cases in the U. S. are found in
     nine New England States, Minnesota and Michigan.

 2. The Texas Department of Health reports an average of 70 human
     cases of Lyme disease in Texas annually, many of which were
     acquired when people traveled outside of the State.                

3.  Julie Rawlings reported in her research on the incidence of the
     Lyme disease organism in Texas State Parks for the Texas
     Department of Health, that the Borrelia buorgdorferi organism is
     not present in sufficient amounts in the suitable tick vector for
     dogs to be at risk of Lyme disease in Texas.

4.  Texas A&M College of Veterinary Medicine has not documented one
     case of Lyme disease in a dog. Screening of shelter dogs by
     Dr Alice Wolf has not demonstrated one case.

5.   Dr Jacobson, Cornell University (ret) has documented a temporal
  relationship     between Lyme vaccine and the development of
  polyarthritis in dogs.

6.   A reasonable client would not elect Lyme disease vaccine for their
   pet if given this information on the risk vs. benefit of the vaccine.

References:

1.    Klingborg, DJ, Hustead DR, Curry-Galvin E, AVMA Council on Biologic and Therapeutic Agents’ Report on cat and dog vaccines, JAVMA, Vol 221, No 10, Nov 15, 2002, pg 1401- 1407.

2.    Greene CE, Schultz RD, Ford, R, Canine Vaccination, Veterinary Clinics of North America: Small Animal Practice, Vol 31, No 3, May 2001, pg 473-  492.

3.    Jacobson RH, Chang YF, Shin SJ, Lyme disease; laboratory diagnosis of infected and vaccinated symptomatic dogs, Seminars in VET Medicine and  Surgery; Small Animal, 11(3); 172-82 Aug 1996.

5.    Schultz, Ronald D., “Current and future canine and feline vaccination programs”, Veterinary Medicine, March 1998, pg.

6.    Wolf Alice, Vaccines of the Present and Future, Proceedings of the World Animal Veterinary Congress, Vancouver 2001

      VI.        Injection site fibrosarcoma is a fatal type of cancer caused by
                     vaccines. Clients should be informed of the risk of a vaccine
                     causing an injection site fibrosarcoma. The vaccination of a
                     cat without informing the customer of the risk of an injection
                     site fibrosarcoma is fraud by omission of a material fact. .
                     Although any injection can result in a fibrosarcoma,
                 adjuvanted vaccines have been determined to be at least five
                 times a higher risk of causing an injection site fibrosarcoma. Clients
                 should be advised of safer alternatives including reduced
                 vaccination schedules, intranasal vaccines, and non-adjuvanted
                 vaccines. The recommendation for vaccination of cats without
                 informed consent is fraud by misrepresentation, misrepresentation
                 by silence, and undue influence as well as cruelty to animals given
                 the literature that states:

1.           Vaccines have been incriminated as a cause of Injection Site Fibrosarcoma in cats.

2.           Adjuvanted vaccines have been demonstrated to be at higher risk.

3.            It is estimated that 1:20,000 cats vaccinated develop vaccine-associated fibrosarcoma.

4.       Injection site fibrosarcomas are 100% fatal if untreated. The prognosis, even with surgery, radiation and chemotherapy is very poor. 

5.            The American Association of Feline Practitioners and the AVMA Vaccine Associated Sarcoma Task Force recommend reduced vaccination schedules and alternative non-adjuvanted and intranasal vaccines. 

6.       A reasonable client would not elect unnecessary or unsafe vaccines for their cat if given this information.

References

1.       O’Rourke Kate, Progress made in feline sarcoma research, JAVMA, Vol. 220, No 6, March 2002.

2.       Bergman P, Hendrick MJ, Macy D, McGill LD, Starr RM, Van Kampen KR, Feline Sarcoma and Vaccination, Veterinary Forum, March 1999,40-47.

3.       Bergman PJ, Etiology of feline vaccine-associated sarcomas, JAVMA, 1998,213, 1424-1425.

4.       Kass PH, Barnes WG, Spangler WL, Epidemiologic evidence for a Causal Relationship Between Vaccination and Fibrosarcoma Tumorigenesis in Cats, JAVMA, 1993,203, 396-405.

5.       Meyer EK, Vaccine Associated Adverse Events, Veterinary Clinics of North America; Small Animal Practice, Vol 31, No 3 May 2001, pg 473-492.

6.       Gaskell R, Gettinby G, Graham S, Skilton D, Veterinary Products Committee working Group on Feline and Canine Vaccination, Department for Food & Rural Affairs, Nobel House London, UK, May 2001

7.    Ford, Richard, Vaccines & Vaccinations Change is in the Wind, Merial Ltd, 2003

VII.  The recommendation for vaccination of cats with Feline
      Infectious Peritonitis vaccine is fraud by misrepresentation,
      misrepresentation by silence, and undue  influence given the
      literature that states:

1.           Feline Infectious peritonitis is a rare disease.

2.            Eight percent of adult cats carry the normal flora a virulent Feline Corona Virus. On rare occasions this Corona Virus mutates to become a virulent feline Infectious Peritonitis Virus. Every mutation is a different variant and there no cross protection. This vaccine does not and cannot work.

3.           Independent studies have not confirmed the manufacturers claims for efficacy.

4.          Twenty- two Schools of Veterinary Medicine, The American Veterinary Medical Association Council on Biologic and Therapeutic Agents and the American Association of Feline Practitioners does not recommend this vaccine.

          5.      A reasonable client would not elect this vaccine if given this
                   information.

References:

1.       Kennedy M, Boedecker N, Gibbs P, Kania S, Deletions of the 7a ORF of feline
corona virus associated with an epidemic of FIP, Vet Microbiology, 81(3): 227-34, Aug. 8, 2001 Department of Comparative Medicine, U of Tenn, CVM.

2.     Kiss I, Kecskemeti S, Tanyi J, Klingeborn B, Belak S, Prevalence and genetic pattern of feline coronavirus in urban cat populations, Vet J 159, (1); 64-70, Jan 2000.Veterinary Institute of Debrecen, Hungary, Harcourt Publishers Ltd, 2000.

3.     Vennema H, Poland A, Hawkins F, Pedersen NC, A comparison of the genomes of FECV and Feline Infectious Peritonitis viruses, Feline Practice, 23,40-44,1995.

4.    Herreewegh AA, Maher M, Hedrich HJ, Haagmans BL, Egberink
       HF, Persistence and Evolution of Feline Corona virus in a closed
 

5.     Richards J, Rodan I, Feline Vaccine Guidelines, Veterinary
        Clinics of North America, Small Animal Practice, Vol 31, No 3,

6.     Rohrbach Barton W, Legendre A M, Epidemiology of Feline
        Infectious Peritonitis Among Cats Examined at Veterinary
       Teaching Hospitals, JAVMA 218, (7): 111-15 April 1, 2001.

7.     Vennema H, Genetic drift and genetic shift during feline
       coronavirus evolution, Vet Microbiology 69(1-2); 139-41 1999
       Sept 1.

8.     Gunn-Moore DA, Gunn-Moore FJ, Gruffydd-Jones TJ, Harbour
        DA, Detection of FeCoV quasaspecies using denaturing  
        gradient gel eletrophoresis, Vet Microbiology 69(1-2): 127-30
        Sept 1, 1999.

9.      Kida k, Hohdatsu T, Fuji K, Koyama H, Selection of antigenic
         variants of the S glycoprotein of FIP virus and analysis of
         antigenic sites involved in neutralization, J Vet Med Sci.
         61(8): 935 – 8 Aug 1999

10.     Vennema H, Poland A, Foley J, Pederson NC, Feline Infectious
         peritonitis viruses arise by mutation from endemic feline
         enteric coronaviruses, Virology 234(1): 150-7, March 30,1998.

11.     Kennedy MA, Brenneman K, Millsaps RK, Black J, Potgieter LN,
         Correlation of genomic detection of feline coronavirus with
         various diagnostic assays for feline infectious peritonitis, J Vet
         Diagn Invest 10(1); 93-7, Jan 1998.

12.     Herreweigh AA, Mahler M, Hedrich HJ, Haagmans Bl, Egberink
         HF, Horzinek MC, Rottier PJ, de Groot RJ, Persistence and
         evolution of feline coronavirus in a closed cat-breeding
         colony, Virology 234(2): 349-63, Aug 4 1997.

13.       Mochizuki M, Misutake Y, Miyanohara Y, Higashihara T, Shimizu
   T, Hodatsu T, Antigenic and plaque variations of serotype II
   feline infectious peritonitis coronavirus, J Vet Med Sci, 59(4):
   253-8, April 1007.

  14.    Klingborg DJ, Hustead DR, Curry-Galvin EA, AVMA Council on
          Biologic and Therapeutic Agent’s report on cat and dog
          vaccines, JAVMA Vol 221, No 10, pg 1407.  November 15,
          2002

  15.    2000 Report of American Association of Feline Practitioners
     and Academy of Feline Medicine Advisory Panel on Feline
     Vaccines, pg. 15 & 16.

VIII.  The recommendation of Feline Immunosupressive virus (FIV) vaccine is fraud by misrepresentation, misrepresentation by silence, and undue influence given the literature that states:

            1. The virus in the vaccine is Clade A & D. The predominate Clade
    found to cause FIP disease in the United States is Clade B.
    Cross protection is poor.

            2. A reasonable client would not elect this vaccine for their cat if
    given this information.

References:

1.Yamamoto, Janet K, Torres Barbara A, Pu Ruiyi, Development of
   the dual-type feline immunodeficiency virus vaccine, AIDScinece
   Vol. 2, No 8, 26 April 2002.

2. Pu Ruiyi, Dual-subtype FIV vaccine, AIDS 15, pg. 1225-37, July
   6, 2001 (Pub Med)

IX      The recommendation for annual Feline Leukemia vaccine for
          indoor only cats, or adult cats without informed consent is
          theft by deception, fraud by omission of material facts, and
          undue influence given the literature that states;

1.   Cats over one year of age are resistant to Feline leukemia virus whether they are vaccinated or not.

2.   Although the duration of immunity of Feline Leukemia vaccine
     is controversial, twenty- two Schools of Veterinary Medicine,
     and the American Association of Feline Practitioners
     recommend this vaccine for at-risk adult cats only.

         References:        

             1. Klingborg DJ, Hustead DR, Curry-Galvin EA, AVMA Council on Biologic
               and Therapeutic Agent’s report on cat and dog vaccines, JAVMA

 2.    Hoover EA, Feline leukemia virus infection: Age related variation in response to infection, Journal of the National Cancer Institute, 57, 365. (1776)

 3.   Hofmann-Lehmann R, Recombinant FeLV Vaccine: Long-term protection effect on course and outcome of FIV infection, Veterinary Immunology Immunopathology, 4691- 2); 127-37 May 1999

4.   2000 Report of American Association of Feline Practitioners and
     Academy of Feline Medicine Advisory Panel on Feline Vaccines.

X.  The recommendation of blood tests for antibody titers on dogs
   and cats in order to determine if re-administration of vaccine is
   indicated is fraud by misrepresentation, misrepresentation by
   silence, and undue influence given the literature that states:

1.                   The duration of immunity to infectious disease agents is controlled by memory cells, B & T lymphocytes.  Once programmed, memory cells persist for life. The presence of memory cells is not taken into effect when testing for antibody titers.

2.                   Even in the absence of an antibody titer, memory cells are capable of mounting an adequate immune response in an immunized patient.  A negative titer does not indicate lack of immunity, or the ability of a vaccine to significantly enhance the immune status of a patient.

3.                   A positive titer has not been demonstrated by challenge studies to indicate immunity.

4.                   The client is paying for a test where the Veterinarian can make no claims as to the significance of a positive or negative test result.

5.                   A reasonable client would not elect to pay for this test if given this information.

References:

1.       Wolf, Alice M., Vaccinations-what’s right? What’s not? Compendium on CE, Schering-Plough Animal Health, 1999, pg. 32,33.

2.   Klingborg Donald, Principles of Vaccination, AVMA Council on Biologic and Therapeutic Agents, Policy on Biologics, April 2002.

3.    Wolf Alice M, Just the Facts About Vaccs: Frequently Asked Questions About Current Vaccination Recommendations and Practice Guidelines, Proceedings from the North American Veterinary Conference, 13, 1999, pg. 681.

    4.     2000 Report of American Association of Feline Practitioners
    and Academy of Feline Medicine Advisory Panel on Feline
    Vaccines, pg. 15 & 16.

  5.   Klingborg, DJ, Hustead DR, Curry-Galvin E, AVMA Council on
     Biologic and Therapeutic Agents’ Report on cat and dog
     vaccines, JAVMA, Vol 221, No 10, Nov 15, 2002, pg 1401- 1407.

       6 .  Paul, Michael, Report of the American Animal Hospital
           Association Canine Vaccine Task Force: 2003 Canine Vaccine
           Guidelines, Recommendations, and Supporting Literature, AAHA
           Foundation, March 2003

The Texas State Board of Veterinary Medical Examiners has reviewed this complaint and found nothing inaccurate or untrue. Despite my repeated requests over the last four years, the

Texas State Board of Veterinary Medical Examiners has failed to take any reasonable and demonstrated action to stop the deceptive trade practices and fraud in the marketing of vaccinations for companion animals. The open letter to Veterinarians approved by the Board February 13, 2003(Enclosed) cannot reasonably be expected to stop Veterinarians from the prevailing fraudulent protect the people of Texas, and whereby it is provided in the Texas Administrative Code Title 22, Part 24, Chapter 577, Subchapter B, Rule 577.16: Responsibilities of the Board (a) The Texas Board of Veterinary Medical Examiners is responsible for establishing policies and promulgating rules to establish and maintain a high standard of integrity, skills, and practice in the profession of Veterinary medicine in accordance with the Veterinary Licensing Act. The Licensing Act clearly provides for the Board to prohibit the prescribing of unnecessary medications. I hereby assert that the Texas State Board of Veterinary Medical Examiners is negligent in its responsibilities.

The Texas State Board of Veterinary Medical Examiners Board has ignored my repeated requests to deny approval of Continuing Education credit where a conflict of interest exists. CE credits should not be allowed for seminars provided by paid employees of drug companies.  Pfizer Animal Health, Fort Dodge Animal Health, and Meriel have provided seminars, which are fraudulent by omission of material facts, misrepresent the scientific data, and thereby influence Veterinarians to continue deceptive trade practices in the marketing of vaccines. (A separate complaint will be filed with your office and the Federal Trade Commission alleging false advertising on the part of these three companies.)

The people of the State of Texas have pay over $360 million dollars per year for vaccinations that are unnecessary and potentially harmful to their pets. Over 2,000 pets die every year from adverse reactions to unnecessary vaccinations. A survey by the American Animal Hospital Association shows that less than 7% of Veterinarians have updated their vaccination recommendations, in spite of the fact that these new recommendations have been published twice in every major Veterinary Medical Journal since 1995.

I am not asking that the Veterinarians of the State be punished. I am requesting that the fraudulent marketing of vaccines and harming of clients pets be stopped.

A reasonable solution would be for the Attorney Generals office to request an Assurance of Voluntary Compliance on the part of each Veterinarian engaged in companion animal practice in the State, agreeing to stop the marketing of vaccines without informed consent, and where no benefit has been scientifically demonstrated.                      

A reasonable solution would be for the Texas State Board of Veterinary Medical Examiners to request an opinion from the Attorney General on these issues, and for the

Texas State Board to issue a policy statement in the Board Notes indicating a Board policy requiring informed consent, and prohibiting deceptive practices as I have outlined above.

                Sincerely,

                        Dr. Robert L. Rogers

                Dr Robert L Rogers

The above statements are true and accurate to the best of my knowledge.
The Studies and Journal Articles referenced are provided.
 

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