ARE FDA AND DoD GETTING AWAY WITH MILITARY EXPERIMENTS — AND NEVER HELD ACCOUNTABLE?
Part 4 of 7 — Shall we all finally do something about it? Federal mandamus files next week.
Interest of Justice — April 17, 2026 — Citizen Petition Series, Part 4 of 7 — Docket FDA-2025-P-1807 (click to open the public docket)
ARE YOU TIRED OF NO ONE HOLDING FDA ACCOUNTABLE FOR THE COVID EXPERIMENTS?
We feel you and are pretty darn sick of the years of no justice ourselves!
Next week with your support we can file a federal mandamus in D.C. District Court.
It FINALLY does what you want & need - it demands FDA finally answer on the record for Operation Warp Speed “vaccine” experiments.
You can help be part of history & support this one of a kind effort that can still win!
Warp Speed used a military-only contracting pathway to dose 670 million civilians.
Congress never authorized it.
A federal judge can force FDA to account for that — but it requires court action that has very little support so far.
YOU CAN HELP IOJ FINALLY HOLD FDA ACCOUNTABLE. STOP THE SHOTS!
As much as IoJ is ready and willing to file - going to court with a filing of this magnitude requires real funds & public support.
If you ever supported - thank you, thank you!!!
THE PROBLEM- IF YOU’RE NEW HERE
Have you ever felt like the covid vax problem is so big its easier to give up?
Do you feel especially frustrated, since nothing is changing after all these years? We feel you. It sucks! But it’s NOT over yet. Read up & keep faith!
IoJ filed a citizen petition — FDA-2025-P-1807 — and the FDA is shamefully lagging on it. They had 180 days to respond. The deadline was December 13, 2025. We are now 305 days in with no substantive answer. If they answered the covid shots would be declared illegal and stopped pronto, so we see why they are ignoring the duty to answer.
We are about to file a federal mandamus in the U.S. District Court for D.C. to force FDA to answer — and along the way, to demand the Congressional report the Department of Defense was legally required to produce before any bio-agent testing on civilians. That report does not exist. Our previous FOIA confirms it.
IoJ is reader-supported. No corporate sponsors, no law firm. The petition runs well over 130 pages of primary filing plus hundreds more pages of exhibits — because FDA itself told petitioners to pack everything into one document. The petition asks the agency to do what it should have done years ago — reclassify mRNA and adenoviral vector products as gene therapy, impose a clinical hold, and fix the record.
This is a seven-part series walking through the petition section by section. Whichever part you landed on, the others are linked.
THIS IS PART 4 OF 7. The full series walks through Citizen Petition FDA-2025-P-1807 section by section. FDA has been silent for 305 days — 125 days past the statutory response deadline.
Part 1 — The Minimal Risk Misclassification
Part 2 — The Gene Therapy Classification Problem
Part 3 — The DoD § 1520a Problem
Part 4 — The Warp Speed Authority Problem (you are here)
Part 5 — The Adulteration and SV40 Problem (coming soon)
Part 6 — The International Law Dimension (coming soon)
Part 7 — The Remedy We Are Asking For (coming soon)
PART 4 - THE OVERVIEW EASY TO UNDERSTAND
Here is what this part is about, in plain English. Operation Warp Speed (OWS) was not an FDA program. It was a DoD program that ran on contracting pathways Congress wrote for military research and prototyping — not for civilian mass deployment. DoD used Other Transaction Authority under 10 U.S.C. § 2371 and accelerated review under Public Law 115-92. Both were written for the armed forces. Both were used to dose 670 million civilians instead. Under the major questions doctrine, an agency cannot take an action of “vast economic and political significance” without clear congressional authorization. Congress never authorized the merger of a military pathway with civilian mass deployment UNLESS THERE IS A SPECIFIC INFORMED CONSENT REPORT FILED FIRST. The OWS pathway was wrong BECAUSE THE DOD & HHS NEVER FILED THE REQUIRED REPORT ALLOWING THEM TO EXPERIMENT ON CIVILIANS WITH TE COVID “VAX”. The downstream FDA EUA “COVID VACCINE” authorizations inherit the defect and are VOID & SO DAMN ILLEGAL! WE CAN FINALLY PROVE IT TO A JUDGE AND WIN TO STOP COVID VACCINES! IT’S A BIG DEAL. LETS ALL STICK TOGETHER - YOU CAN STILL HELP US FILE THE CASE & DO THE JOB RIGHT!
FOR THE DIEHARDS — THE FULL ANALYSIS
The long version — with the statutory text and the case law — is below.
Operation Warp Speed was not an FDA program. It was a Department of Defense-led development and manufacturing program that used contracting authority Congress created for military research and prototyping — not for civilian mass deployment. The pathway was called Other Transaction Authority, or OTA. The expedited review framework was further accelerated by Public Law 115-92, a December 2017 statute amending the Department of Defense’s authority to contract for medical research. Neither authority was written for mass civilian vaccination. Both were used that way anyway.
When an agency uses a military pathway for civilian deployment that Congress never authorized, the pathway is not accelerated — it is absent.
Part 3 showed that 50 U.S.C. § 1520a required Congressional reports before any DoD-led biological agent testing on civilians, and that those reports were never filed. Part 4 addresses the separate but connected problem — the contracting and review pathway DoD used, and whether it legally applied to civilian administration at all. This is what Citizen Petition FDA-2025-P-1807 asks FDA to address on the docket — and what FDA has refused to address for 305 days running.
A. WHAT OTA AUTHORITY WAS ACTUALLY FOR
Other Transaction Authority is codified at 10 U.S.C. § 2371 and 10 U.S.C. § 2371b. It was created to allow the Department of Defense to enter into “other transactions” for research and prototyping outside of the standard Federal Acquisition Regulation framework. The purpose was narrow — DoD needed flexibility to work with nontraditional defense contractors, universities, and small innovators on experimental technologies. The tradeoff was that OTA agreements are not subject to standard procurement competition requirements, standard Bayh-Dole intellectual property provisions, or the full disclosure framework that attaches to conventional procurement contracts.
Congress gave DoD that flexibility on the explicit understanding that it was for research and prototyping — discrete, limited-quantity, experimental development work. The statute did not authorize mass production. The statute did not authorize civilian deployment. The statute did not authorize use of OTA as a vehicle for procuring a biological agent for administration to the general population of the United States. That is not what it was designed to do, and the legislative history is unambiguous on the point.
B. PUBLIC LAW 115-92 AND WHAT IT AUTHORIZED
Public Law 115-92, enacted December 12, 2017, amended 21 U.S.C. § 360bbb-3 — the Emergency Use Authorization statute — to create a secondary expedited pathway specifically for products intended for use by members of the armed forces. The operative language authorized expedited review of certain products where the Secretary of Defense determined that the product was needed to respond to a military-specific emergency threat. The provision was sought by DoD to streamline review of countermeasures for operational military risks — battlefield exposures, chemical and biological warfare agents, endemic disease in deployment theaters.
The provision explicitly contemplated a military population. It did not contemplate use of the same pathway to accelerate review of products intended for the general civilian population of the United States. A close reading of the legislative history of the 2017 amendment confirms that Congress was specifically concerned with closing the gap for uniformed service members exposed to military-specific threats — not opening a universal expedited pathway that could be triggered for any public health event.
Public Law 115-92 was a military-specific pathway. Operation Warp Speed used it for civilians. That extension of authority is what the petition asks FDA to address on the record.
C. THE IMPERMISSIBLE MERGER
What happened in 2020 was that DoD executed OTA contracts with Moderna, Johnson & Johnson, and other manufacturers for the development and manufacturing of COVID-19 vaccines, while the Emergency Use Authorization infrastructure — including elements of the 115-92 military-accelerated pathway — was used to expedite FDA review. The two authorities were functionally merged. The OTA contract framework provided the procurement and manufacturing speed. The 115-92 elements provided the review acceleration. Neither authority, standing alone, authorized the civilian mass administration that followed.
This is the “impermissible merger” problem the petition puts on the docket. It is a straightforward administrative law question. Under the major questions doctrine reaffirmed in West Virginia v. EPA (2022), agency action of “vast economic and political significance” requires clear congressional authorization. Mass administration of a novel biological product to hundreds of millions of civilians is the paradigm case. Neither OTA nor Public Law 115-92 provides the required clear authorization for civilian mass deployment. The agencies had to find it somewhere else. They did not.
And here is the part that makes the merger worse. The products running through the Warp Speed pipeline are biological agents under federal statute. Section 1520a defines a biological agent as “any micro-organism (including bacteria, viruses, fungi, rickettsiae, or protozoa), pathogen, or infectious substance, and any naturally occurring, bioengineered, or synthesized component of any such micro-organism, pathogen, or infectious substance.” The Biological Weapons Anti-Terrorism Act at 18 U.S.C. § 178 adds the harm criterion — any such agent “capable of causing death, disease, or other biological malfunction in a human, an animal, a plant, or another living organism.” Both definitions fit the mRNA and adenoviral vector products that went through Warp Speed. Synthetic nucleic acid sequences that instruct cells to produce a spike glycoprotein are bioengineered components of pathogens. VAERS data, FDA’s own briefing documents, and peer-reviewed spike-protein literature establish the harm criterion is met.
So the merger was not just an administrative-law problem. It was a biological-agent deployment through a procurement pathway Congress wrote for research and prototyping — not for civilian mass administration of products the federal code itself classifies as biological agents capable of causing death and disease. Two separate statutes, one conclusion. The products fit the definition. The pathway did not authorize the deployment. The chain fails at every link.
D. HOW THE EUA DOWNSTREAM INHERITED THE DEFECT
FDA’s Emergency Use Authorization decisions rested on the upstream DoD-led development and manufacturing program. The products FDA reviewed were products produced through OTA contracts executed under the Warp Speed framework. The data FDA reviewed was data generated in accelerated trials running on the 115-92 elements. The agency did not independently regenerate the clinical trial data. The agency reviewed what was provided.
If the upstream development and manufacturing program exceeded its statutory authority — and the petition argues it did — then the EUAs rest on data and products produced through an unauthorized pathway. This is not a “gotcha” argument. It is the default administrative law rule. Where an agency’s action depends on a predicate authority, and the predicate authority fails, the downstream action inherits the defect. Department of Transportation v. Association of American Railroads, 575 U.S. 43 (2015), and the broader non-delegation framework address the same concern from a different angle.
FDA’s response to this argument, if it ever produces one, will likely turn on some version of severability — the claim that even if the DoD authority was defective, FDA’s EUA authority stands independently because EUAs require only that FDA determine a product is “reasonable to believe effective” under its own statutory framework. That response does not work. FDA did not run the trials. FDA did not produce the product. FDA reviewed what DoD and the manufacturers produced. If the produced product came from a defective pathway, the review inherits the defect.
E. THE INFORMED CONSENT WAIVER PIGGYBACKED ON THE DoD PATHWAY
Part 1 laid out the ultra vires waiver of informed consent under the minimal risk provision. Part 3 addressed the parallel violation under 10 U.S.C. § 1107 affecting uniformed service members. Part 4 closes the loop — the informed consent waiver was functionally enabled because the product was administered through a military-accelerated pathway that, when leveraged for civilians, was used to justify reduced disclosure. The argument went roughly — this is an emergency, this is an unapproved product under EUA, and the framework for full informed consent that applies to conventional drug approval does not strictly apply.
The argument collapses under 21 U.S.C. § 360bbb-3(e)(1)(A)(ii)(III), which preserves — even within the EUA framework — the “option to accept or refuse administration of the product.” Congress anticipated that expedited review under emergency authority might tempt agencies to shortcut informed consent. Congress wrote the preservation clause specifically to prevent the shortcut. The preservation clause applied. It was not enforced.
Congress saw this problem coming in 1997 when it wrote the Emergency Use Authorization framework. Congress said — even in emergencies, the option to accept or refuse administration is preserved. The agencies ignored the clause. That is the record.
F. WHAT WARP SPEED WAS ACTUALLY AUTHORIZED TO DO
Separate from the broader question of civilian mass deployment, the OTA contracting framework had specific contractual limitations that appear not to have been enforced. OTA agreements do not require manufacturers to comply with Current Good Manufacturing Practice in the same way conventional procurement contracts do. OTA agreements allow intellectual property and liability terms to be negotiated outside standard federal frameworks. OTA agreements do not trigger the standard disclosure and transparency requirements that attach to FDA-regulated biologics manufactured under conventional contracts.
What this means in practice is that the production chain used for the COVID-19 mRNA and adenoviral products was not subject to the same regulatory oversight as products produced under conventional biologics manufacturing contracts. FDA’s EUA review did not independently inspect the OTA-contracted manufacturing. FDA reviewed summary manufacturing data provided by sponsors. The agency never independently enforced Current Good Manufacturing Practice standards at the OTA-contracted facilities to the degree it would have for a conventionally procured biologic.
This matters for the adulteration analysis Part 5 will take up — because the DNA contamination and SV40 promoter findings documented by Dr. Janci Lindsay and replicated by independent laboratories were not caught by the manufacturing oversight regime that should have been in place. The oversight regime was not in place because the manufacturing was contracted under a pathway designed for military research prototyping, not mass civilian production.
THE QUESTIONS FDA MUST ANSWER
1. What statutory authority permitted use of Other Transaction Authority under 10 U.S.C. § 2371 for mass civilian deployment of COVID-19 vaccines, given that OTA was authorized for “research and prototyping”?
2. What statutory authority permitted use of Public Law 115-92 — a pathway authorized for products “for use by members of the armed forces” — to accelerate review of products for administration to civilians?
3. Under the major questions doctrine articulated in West Virginia v. EPA, where is the clear congressional authorization for the civilian mass administration that followed from the Warp Speed pipeline?
4. How does FDA reconcile its EUA decisions with the preservation clause in 21 U.S.C. § 360bbb-3(e)(1)(A)(ii)(III), which guarantees the option to accept or refuse administration of the product?
5. Did FDA independently enforce Current Good Manufacturing Practice standards at OTA-contracted COVID-19 vaccine production facilities? If so, where are the inspection reports in the administrative record?
6. If FDA takes the position that severability preserves the EUAs independent of any Warp Speed authority defects, will the agency identify the specific independent statutory predicate that supports each authorization?
DID YOU KNOW? EXPOSING THE DOD DEMONS>
• Other Transaction Authority contracts are not subject to the standard Federal Acquisition Regulation framework. They do not require cost accounting standards compliance, do not require standard Bayh-Dole intellectual property provisions, and do not trigger the full disclosure regime that attaches to conventional defense procurement.
• Public Law 115-92 was originally enacted as part of the Continuing Appropriations Act, 2018, and Supplemental Appropriations for Disaster Relief Requirements. The military expedited review provision was a discrete amendment inserted to address operational military countermeasure needs.
• The Congressional Research Service has published multiple reports on OTA authority and its limitations. See CRS R47026, “Other Transactions (OT) Authority.” The reports are unambiguous on the “research and prototyping” scope.
• DoD’s Operation Warp Speed Joint Program Office retained significant operational control over the vaccine development pipeline that would normally have sat with HHS and FDA. This structure was unprecedented in civilian biologics development.
THIS WEEK — IF YOU EVER WANTED TO HELP US STOP THE COVID NON VACCINES, NOW IS WHEN YOU ARE NEEDED TO HELP STEP IN!
This is the fundraising week that can help get this case to the federal courthouse.
IoJ hates fundraising - it’s the other F word - haha!
To be honest, this problem is huge (you already know that - and are super frustrated just like we are).
The solution of filing in court still needs more hero’s to care and become paid subscribers or help with monthly or one-time donations to make this happen.
If this work matters to you, this is the week to show up and support this unique & solid lawsuit to stop the shots!
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As much as IoJ is ready and willing to file - going to court with a filing of this magnitude requires real funds & public support.
Share this series with a doctor, a lawyer, a reporter, a member of Congress, a state AG. The petition is public at regulations.gov/docket/FDA-2025-P-1807. The argument is on paper. The record is already there & NEEDS A COURT TO STEP IN TO MAKE THINGS RIGHT FOR US ALL - ITS A GLOBAL SOUL-UTION.
FDA WAS THE SOURCE GLOBALLY. LETS STOP THEM & UNWIND THIS MESS!
If you can pray on this one, pray. If you can fund it, fund it. If you can share it, share it. Whatever you can offer is what will help us fuel the fight!
Part 5 is drafted. The Adulteration Problem and What No One Disclosed. Dr. Janci Lindsay found SV40 promoter sequences. Independent labs replicated her findings. Under 21 U.S.C. § 351, a product with undisclosed components is adulterated.
Part 5 walks through what adulteration means, what the findings actually show, and why the informed consent framework requires disclosure. FDA is hiding.
Do not join them. EXPOSE THEM!!!
— Interest of Justice
RELATED READING
The citizen petition itself
• First Citizen Petition — FDA-2022-P-2411 (September 2022 + January 2023 amendment)
• Consolidated Petition — FDA-2025-P-1807 (June 17, 2025)
The federal mandamus
• BREAKING — IoJ is Taking FDA, HHS and DoD to Federal District Court After FDA’s Delay on Petition
• Three-Day Countdown For U.S. To Sue The WHO — IoJ Suing WHO, FDA, HHS, DoD
• Six-Day Countdown For U.S. To Sue The WHO — Nuremberg Hearing Project
• What Happens When You Actually Legally Win — Judicial Testimony Under Oath
• Justice Plans Delayed and Resuming BIG TIME Now
Gene therapy classification and FDA
• BREAKING!! FDA Issues Gene Therapy Guidance While Refusing to Answer if mRNA is Gene Therapy
• FDA Demands Big Pharma Prove Flu Vaccines Work — While Refusing to Answer If mRNA Is Gene Therapy
Department of Defense, FOIA, Operation Warp Speed
Adulteration, SV40 and DNA contamination
• Crimes Against Humanity Case Phase 1 — DNA Integration Into Ovaries Chromosomes 19 and 12 Confirmed
• HUGE! Regulator Health Canada Confirms Undisclosed DNA Sequence in Pfizer Shot
• Undercover — Pfizer’s Principal Scientist Admitting They Skipped Ten Years of Safety Testing
Nuremberg Code, Costa Rica, and the international accountability proceeding
• Judge Orders Nuremberg Public Hearing — Interest of Justice v. State of Costa Rica
• One Year Ago Today — Nuremberg Hearing November 11, 2024
• The Court Victory That Shattered WHO’s Global Authority — Next Step Nuremberg Hearing Project
• VP and Health Minister Answer Judges About Safety After Promoting Yearly mRNA
• Achieving Global COVID Justice — Conversation With Interest Of Justice and Dr. Ana Mihalcea
WHO, IHR amendments, pandemic treaty, global governance
• Interest of Justice Has Established Strict Limits For The WHO
• We Are W.H.O. Recognized Stakeholders, But IOJ Was Not Invited To Davos
• Six Days Coming Up — Everything HORRIBLE About The WHO’s IHR Amendments and Pandemic Treaty
• NEW ZEALAND Officially REJECTS WHO’s International Health Regulations
• Two Governments Exit WHO and Call It Sovereignty — Pandemic Treaty Is Near Dead
• Hey Ho The WHO Have To GO — with James Roguski
• Dear Tedros — What The Hell Does Equity Mean in the IHR Amendments and Treaty?
• Sign Now — 50 Persistent Risks In WHO Proposed Pandemic Agreement
• Today Is World Health Day — But The WHO Runs A World Health Experimentation Program
Amsterdam, Gates, Bourla, and the European accountability proceeding
• Today in Amsterdam — Gates and Bourla Are Being Held To Account In Court
• Appeal Against Gates and Pfizer CEO Filed — To Hear Bioweapon Witnesses Evidence In Court
• Bill Gates and Pfizer CEO Lawsuit Follow-Up — What Actually Happened in Court on March 9
Expert voices — Dr. Yeadon, Dr. Lindsay, Sasha Latypova
• Dr. Yeadon — We Are All Under Assault by Deranged People
• Dr. Yeadon Explains For First Time How COVID Tests Cannot Detect Proteins Like WHO Purports
• Dr. Mike Yeadon About To Go Live From Vienna — Blowing The Lid On Vaccine Injuries
• Dr. Yeadon — There Is No More Important and Urgent Cause Than This
• Kevin McKernan — independent sequencing replication of SV40 findings
Pfizer accountability and the broader pharma record
• Do Not Let Pfizer Get Away With The Biggest Crime In History — DailyClout Pfizer Documents Analysis
• The Covert Killers and Their Secret Plans For You and Your Families
• Sketchy Door-to-Door COVID Vaccine Sweeps in Costa Rica
Primary sources — statutes, regulations, case law
• 21 CFR § 10.30 — FDA citizen petition regulations
• 21 CFR § 600.3(h)(5) — FDA’s gene therapy regulatory definition
• 21 CFR Part 50 — FDA informed consent regulations
• 21 CFR § 312.42 — FDA clinical hold authority
• 21 U.S.C. § 351 — federal adulteration standard
• 21 U.S.C. § 360bbb-3 — Emergency Use Authorization statute
• 42 U.S.C. § 262 — Public Health Service Act biologics regulation
• 42 U.S.C. § 247d-6d — PREP Act liability framework
• 50 U.S.C. § 1520a — prohibition on DoD bio-agent testing on civilians
• 10 U.S.C. § 1107 — military informed consent statute
• 10 U.S.C. § 2371 — Department of Defense Other Transaction Authority
• 28 U.S.C. § 1361 — federal mandamus jurisdiction
• 5 U.S.C. § 706 — Administrative Procedure Act judicial review
• Public Law 115-92 (December 12, 2017) — military expedited review
• Cruzan v. Director, 497 U.S. 261 (1990)
• Washington v. Glucksberg, 521 U.S. 702 (1997)
• Washington v. Harper, 494 U.S. 210 (1990)
• Loper Bright v. Raimondo (2024) — post-Chevron framework
• Motor Vehicle Mfrs. Ass’n v. State Farm, 463 U.S. 29 (1983)
• West Virginia v. EPA (2022) — major questions doctrine
• Utility Air Regulatory Group v. EPA, 573 U.S. 302 (2014)
• Youngstown Sheet & Tube Co. v. Sawyer, 343 U.S. 579 (1952)
• Telecommunications Research & Action Center v. FCC, 750 F.2d 70 (D.C. Cir. 1984) — TRAC factors
International law and bioethics
• ICCPR Article 7 — International Covenant on Civil and Political Rights
• UN Human Rights Committee General Comment No. 20
• Nuremberg Code — full text (NEJM)
• UNESCO Universal Declaration on Bioethics (2005)
• Convention Against Torture (OHCHR)
FDA guidance and public data
• FDA — Long Term Follow-Up After Administration of Human Gene Therapy Products (2020 guidance)
• Zolgensma approval record (FDA gene therapy comparator)
• Moderna 10-K SEC Filings (EDGAR)
• VAERS — Vaccine Adverse Event Reporting System database
Yes! Under the Umbrella of National Security!
Excellent information. Thank you