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C. Scott Tocher, Interim Counsel
California Institute for Regenerative Medicine
210 Kings Street
San Francisco, CA 94107

RE: Third Re-comment on CIRM Medical and Ethical Standards regulations

Dear Mr. Tocher,

On behalf of the Pro-Choice Alliance for Responsible Research and the Center for Genetics and Society, we are submitting these third re-comments to the proposed California Institute of Regenerative Medicine's Medical and Ethical Standards regulations 17 Cal. Code of Regs §100095.

The regulations offer three options for additional requirements for CIRM-funded egg extraction and stem cell derivation.

We strongly support only Option 3 for the following reasons:

Proposition 71 prohibits compensation for women who provide eggs, and Options 1 and 2 violate both the letter and the spirit of California law.

Proposition 71 clearly requires that the ICOC develop "standards prohibiting compensation to research donors." Options 1 and 2 create exceptions to the law which are not authorized in the statute. In common usage and professional terminology the "donor" is the woman who provides eggs for another woman's fertility purposes. The paid "donors" in the fertility setting are paid for...