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This paper is partially funded by Naval Postgraduate School's Research Initiation Program.

Brent Olde and Amelia Weinreb both provided useful insights in the preparation of this paper. Craig Martell, James Migletz, Beth Rosenberg and Adam Slagell all provided important feedback. Drafts of this paper were reviewed by Associate Professor Paul Ohm at University of Colorado Law School and by James M. Miller, an SAIC senior policy, program and legal analyst.

The author has worked with IRBs at MIT, Harvard and NPS; the author is curently a member of the NPS IRB.

Simson L. Garfinkel 2008-03-21