Why Alina Chan’s Case For A Lab Leak Being SARS-CoV-2’s Origin Fails on The Merits

Today a piece of mine was published by FAIR, criticizing the New York Times’ recent coverage of the Lab Leak Theory.

While it touched on some of the arguments made by Dr. Alina Chan in her guest essay “Why the Pandemic Probably Started in a Lab, in Five Key Points”, it was a more broadly oriented media criticism piece, so I wasn’t able to go into full detail of the issues present in Chan’s arguments.

Those issues, however, are important and deserve to be addressed in a comprehensive manner, so I decided I would publish this as a sibling piece, going point by point in addressing all the deficiencies that plague the Times’ guest essay.

So, with all that established, let’s get into the meat of things and start talking about the case presented for a likely Lab Leak Origin to SARS-CoV-2.

A WEAK OPENING

As the title implies, Chan’s case focuses on 5 main points:

1. “The SARS-like virus that caused the pandemic emerged in Wuhan, the city where the world’s foremost research lab for SARS-like viruses is located.”
2. “The year before the outbreak, the Wuhan institute, working with US partners, had proposed creating viruses with SARS‑CoV‑2’s defining feature.”
3. “The Wuhan lab pursued this type of work under low biosafety conditions that could not have contained an airborne virus as infectious as SARS‑CoV‑2.”
4. “The hypothesis that Covid-19 came from an animal at the Huanan Seafood Market in Wuhan is not supported by strong evidence.”
5. “Key evidence that would be expected if the virus had emerged from the wildlife trade is still missing.”

Her argument begins by bringing up the fact that SARS-CoV-2 emerged in Wuhan, China, the same city in which the Wuhan Institute of Virology (WIV) is located, while asserting the rarity of bat coronaviruses spilling over into humans:

• “At the Wuhan Institute of Virology, a team of scientists had been hunting for SARS-like viruses for over a decade, led by Shi Zhengli. Their research showed that the viruses most similar to SARS‑CoV‑2, the virus that caused the pandemic, circulate in bats that live roughly 1,000 miles away from Wuhan.”
• “Scientists from Dr. Shi’s team traveled repeatedly to Yunnan province to collect these viruses and had expanded their search to Southeast Asia. Bats in other parts of China have not been found to carry viruses that are as closely related to SARS-CoV-2. Even at hot spots where these viruses exist naturally near the cave bats of southwestern China and Southeast Asia, the scientists argued, as recently as 2019, that bat coronavirus spillover into humans is rare.”

NYT: By Jonathan Corum | Sources: Spyros Lytras et al., Science; Sarah Temman et al., Research Square

While spillover events like this aren’t the most common occurrence, they’re also not unheard of. The SARS-CoV-2 outbreak came in the aftermath of several others that were the result of bat-borne viruses, including “Hendra, Nipah, Marburg, SARS-CoV, MERS-CoV (Middle East respiratory syndrome) and Ebola.”

A 2023 study on sarbecoviruses — the subgenus to which SARS-CoV-2 belongs — also indicates that spillovers may not be as rare as Chan states.

Lab Leaks, on the other hand, seem to be exceedingly rare, so much so that they have their own short Wikipedia page listing known instances of them.

They gain copious news coverage when they do occur, with most instances resulting in single infections which are quickly self-reported and self-contained.

On top of that, Wuhan is also home to the Huanan wet market which proponents of the Zoonotic Spillover theory have identified as the likely point of origination for SARS-CoV-2. The market sold wild animals, notably raccoon dogs and pangolins, that can carry coronaviruses and are sometimes sourced from Yunnan.

Given those facts, this beginning portion does very little to set the foundation for a compelling case.

SELECTIVE REFERENCES

Worse still are her selective references surrounding Dr. Shi Zhengli, a senior research scientist at the WIV who caught significant public attention as a result of discussions surrounding a possible lab leak. Chan mentions Shi’s worries surrounding whether or not the novel coronavirus had escaped from her lab early on into the outbreak:

• “When the Covid-19 outbreak was detected, Dr. Shi initially wondered if the novel coronavirus had come from her laboratory, saying she had never expected such an outbreak to occur in Wuhan.”

This completely leaves out the vital context from later in the very same article linked to by Chan that, in accordance with her worry, Shi says she went through the lab’s records to check if it could have been the source, and found that it couldn’t have stemmed from there:

• “Shi instructed her group to repeat the tests and, at the same time, sent the samples to another facility to sequence the full viral genomes. Meanwhile she frantically went through her own lab’s records from the past few years to check for any mishandling of experimental materials, especially during disposal. Shi breathed a sigh of relief when the results came back: none of the sequences matched those of the viruses her team had sampled from bat caves. “That really took a load off my mind,” she says. “I had not slept a wink for days.””

Photo by Johannes Eisele/AFP/Getty Images | Chinese virologist Shi Zhengli photographed inside a laboratory at the Wuhan Institute of Virology in Wuhan, China, in 2017.

At another point, Chan asserted that Shi’s group had published a database containing descriptions of “over 22,000 wildlife samples”, but that the database was taken offline in fall of 2019, around the same time as the pandemic began. The implication is clear, that this action was taken in order to hide the presence of SARS-CoV-2, or a virus close enough to be its predecessor, in WIV custody.

Again, Chan doesn’t present the other side of the discussion. Not once does she mention the reason given for this server’s take down, that repeated hacking attempts at the onset of the pandemic led the institute to take their databases offline out of fear that they may be compromised. Nor does she address Shi’s claim that the databases only contained already published material:

• “Shi told me that the part of the databases that had been publicly available before the pandemic contained only published information; the Wuhan institute, like research organizations in other parts of the world, had unpublished data that could be shared upon request via portals for academic collaborations. The institute, she says, took the databases offline because of security concerns; there had been thousands of hacking attempts since the beginning of the pandemic. “The IT managers were really worried somebody might sabotage the databases or, worse, implant virus sequences for malicious intent,” she said.”

If Chan wants to assert that these are all lies told in defense of a Chinese coverup of SARS-CoV-2’s origination from a lab, that is an argument one can present, but to not even engage with these statements belies a biased and selective presentation of information that undermines the integrity of her position.

THE RESUSITATION OF A DEAD PROPOSAL

From here Chan moves on to the second portion of her argument, focusing on a talking point that should be familiar to anyone who has been keeping up with the cyclical resurgences of the Lab Leak theory over the last few years.

Said point being the existence of a leaked 2018 research proposal by the name of DEFUSE, which was published by the Intercept in 2021.

Chan presents the proposal as a damning piece of evidence, one that other points in favor of a Lab Leak are built upon. She states that it presents a plan to create viruses “shockingly similar to SARS-CoV-2”, placing special focus on the furin cleavage site (FCS) in its spike protein, a point we will return to later.

She goes on to discuss how an early draft of the plan said the WIV would do their virus work in BSL-2 labs, asserting “If the virus had escaped from a BSL-2 laboratory in 2019, the leak most likely would have gone undetected until too late.”

She doesn’t mention, however, the fact that work on the FCS insertion was proposed to have been done in the U.S. — (though this was a detail seemingly open to change to have work done in the Wuhan, according to comments from Peter Daszak present in an earlier draft of the proposal.)

Importantly, Chan admits that the plan never actually received funding as it was rejected but posits that the WIV still could have pursued research like it, referencing a statement from Dr. Fauci where he says that the Wuhan institute did not need to rely on U.S. funding to do independent research in order to reinforce her point.

There are quite a few issues with this section of the argument, for one Chan engages in a large amount of conjecture stacking, placing unsubstantiated claim a top unsubstantiated claim until she has produced a Jenga tower of an argument that looks compelling at a glance but sits upon a crumbling foundation.

For instance, this entire narrative relies on the fact that present in the WIV at any point before the pandemic was a virus similar enough in structure to have become SARS-CoV-2, but Chan never presents any evidence of this being the case.

None of the known viruses within the WIV’s catalog could have been the progenitor, with even the closest virus there — RatG13 — merely seeming to share a common ancestor:

• “There is no rational experimental reason why a new genetic system would be developed using an unknown and unpublished virus, with no evidence nor mention of a SARS-CoV-2-like virus in any prior publication or study from the WIV (Ge et al., 2012; Hu et al., 2017; Menachery et al., 2015), no evidence that the WIV sequenced a virus that is closer to SARS-CoV-2 than RaTG13, and no reason to hide research on a SARS-CoV-2-like virus prior to the Covid-19 pandemic. Under any laboratory escape scenario, SARS-CoV-2 would have to have been present in a laboratory prior to the pandemic, yet no evidence exists to support such a notion and no sequence has been identified that could have served as a precursor.”

Chan just hand waves this, gesturing towards the possibility of the WIV having hidden viruses not known to the public or other research bodies.

Perhaps that’s good enough for an initial questioning of the possibilities or for the plot of a YA mystery novel, but enough to say a lab leak is the most probable origin, certainly not.

DISTORTED ACCUSATIONS

To bolster the likelihood of this claim, Chan relies on assertions surrounding the uniqueness of SAR-CoV-2’s FCS — aiming to put forth the idea that it was the result of lab engineering as opposed to natural development — and mentions reports of scientists from the WIV becoming ill with “Covid-like symptoms” in fall of 2019.

The point relating to the sick scientists is possibly the most manipulative in the entire piece. Chan states that “one alarming detail — leaked to the Wall Street Journal and confirmed by current and former US government officials — is that scientists on Dr. Shi’s team fell ill with Covid-like symptoms in the fall of 2019.”

This telling of the story is grossly lacking in detail, if you only read the WSJ article Chan links to you may be convinced that these cases are more serious evidence than there is truly credence for.

However, upon looking at the IC report from which these claims of sick researchers originate, the weakness of this narrative becomes crystal clear. At one point, the report presents this informational gem:

• “While several WIV researchers fell mildly ill in Fall 2019, they experienced a range of symptoms consistent with colds or allergies with accompanying symptoms typically not associated with COVID-19, and some of them were confirmed to have been sick with other illnesses unrelated to COVID-19. While some of these researchers had historically conducted research into animal respiratory viruses, we are unable to confirm if any of them handled live viruses in the work they performed prior to falling ill.”

So the intelligence community was unable to establish that any of the researchers actually had COVID-19. In fact, they collected information that showed researchers presented with symptoms out of line with COVID and in line with colds or allergies, with some of them even being confirmed to having been sick with unrelated illnesses, all in the midst of flu season.

The report also reaffirms that there is no evidence currently available that the WIV was ever in possession of a virus capable of being the precursor to SARS-CoV-2 nor of any specific research incidents that could have resulted in the pandemic:

• “Prior to the pandemic, we assess WIV scientists conducted extensive research on coronaviruses, which included animal sampling and genetic analysis. We continue to have no indication that the WIV’s pre-pandemic research holdings included SARSCoV-2 or a close progenitor, nor any direct evidence that a specific research-related incident occurred involving WIV personnel before the pandemic that could have caused the COVID pandemic.”

Its misrepresentations as far as the eye can see.

A NOT-SO-ENGINEERED FURIN CLEAVAGE SITE

So, what about the Furin Cleavage Site, what is it and why do people think this one is engineered?

It’s worth going into some depth on this point specifically, as its one of the core contentions often brought forth by people seeking to challenge a natural origin explanation.

SARS-CoV-2’s spike protein consists of 2 sub-units (S1 and S2). Between those sub-units is a region referred to as the S1/S2 site. This site is recognized by a human protease called “furin” which then cleaves the spike protein, in turn producing 2 functional sub-units. After this, another protease called “TMPRSS2” cleaves at the S2 site, with cleavage of both sites being required for viral entry into the cell.

The primary reason this FCS receives so much attention in SARS-CoV-2 is that it is the only virus in the sarbecovirus sub-genus of betacoronaviruses to contain one, a trait absent in its closest relatives.

Seems pretty convincing, right? Well, no not really, let's explore why.

It is worth mentioning that when it comes to viruses the current sampled population represents a small minority of total viruses present in the wild.

The lineage of coronaviruses related to SARS-CoV-2 specifically has an under-sampling problem, and FCS like it are present in viruses such as HCoV-OC43 and HCoV-HKU1 which belonging to other subgenus betacoronavirus groups.

Scientists have also already identified plausible reasons for its presence in SARS-CoV-2, specifically in the form of recombination.

Recombination is a process that allows for genetic exchange between different viruses, resulting in a new viral genome which shares genetic information from both parental strains. The process requires the presence of 2 (generally distinct) viruses in a host cell and is often thought to occur via copy-choice error — an error that can happen when viruses copy their genetic material using an enzyme known as polymerase.

Source: The Conversation | Graph Showing Distinction Between Recombination and Accumulated Mutations

What’s more is that certain sequences — referred to as palindromes due to their shared trait of reading the same forward and backward — are specifically susceptible to copy-choice error, and guess what virus had just such a palindrome present in its genome?

That’s right, SARS-CoV-2 contains a palindromic sequence (CAGAC) around its FCS, and that palindrome matches one in the bat coronavirus HKU9. HKU9 is also known to infect bats that live alongside bats infected with viruses closely related to SARS-CoV-2. With all that in mind, there’s a feasible case to be made that SARS-COV-2 developed a FCS via copy-choice-error-mediated recombination with an ancestor of the bat coronavirus HKU9.

Source: A palindromic RNA sequence as a common breakpoint contributor to copy-choice recombination in SARS-COV-2

The best addressal of claims surrounding the FCS being the result of lab engineering probably came in the form of a 2021 critical review of SARS-CoV-2’s origin, published in Cell. In it they discuss the many reasons for why the site was likely naturally emergent, as it has several inefficient features as well as practical barriers that make it unlikely to be the result of an engineered insertion.

They identify that the mechanism the WIV has been known to commonly use for isolating viruses in the past— serial amplification in Vero E6 cells — has consistently resulted in the loss of the SARS-CoV-2 FCS, as well as point out that in comparison to FCSs present in viruses such as HCoV-HKU1, SARS-CoV-2’s FCS is functionally sub-optimal:

• “The SARS-CoV-2 furin cleavage site (containing the amino acid motif RRAR) does not match its canonical form (R-X-R/K-R), is suboptimal compared to those of HCoV-HKU1 and HCoV-OC43, lacks either a P1 or P2 arginine (depending on the alignment), and was caused by an out-of-frame insertion (Figure 2). The RRAR and RRSR S1/S2 cleavage sites in feline coronaviruses (FCoV) and cell-culture adapted HCoV-OC43, respectively, are not cleaved by furin (de Haan et al., 2008). There is no logical reason why an engineered virus would utilize such a suboptimal furin cleavage site, which would entail such an unusual and needlessly complex feat of genetic engineering.”

All in all, the case for an engineered Furin Cleavage Site seems to be quite scant, especially considering the evidence present for recombination being the explanation for its out of frame insertion in SARS-CoV-2.

EVIDENCE ON TRIAL

It’s at this point that Chan shifts her focus to downplaying the quality of evidence present on the zoonotic spillover side of the origin argument. This is necessary as the case for the lab leak side that has been established so far is wobbly to be charitable.

Here, she starts by claiming that assumptions of Chinese investigators believing the outbreak had initiated at a central market early into the pandemic led to biased data collection that likely resulted in cases unlinked to the market being missed.

• “In December 2019, Chinese investigators assumed the outbreak had started at a centrally located market frequented by thousands of visitors daily. This bias in their search for early cases meant that cases unlinked to or located far away from the market would very likely have been missed. To make things worse, the Chinese authorities blocked the reporting of early cases not linked to the market and, claiming biosafety precautions, ordered the destruction of patient samples on January 3, 2020, making it nearly impossible to see the complete picture of the earliest Covid-19 cases.”

She links to a Letter to the Editor of the Journal of the Royal Statistical Society Series A criticizing one of the major papers in favor of a zoonotic spillover origin for SARS-CoV-2 — Woroby et al, 2022— on the ground that it suffered from a large degree of proximal ascertainment bias but fails to mention the rebuttal produced by one of the paper’s authors alongside another researcher.

This failure is repeated when Chan links to a paper challenging the centrality of the Huanan market in early COVID-19 cases but doesn’t mention a March 2024 commentary produced by Worobey and Debarre addressing this very contention.

Even if Chan has valid arguments against these rebuttals — if she does, I’m unaware of them—but chose not to go into detail due to length considerations, they should still have been mentioned if for no other reason than giving readers the context that they exist.

In another 2021 article referenced in Worobey et al. 2022, lead author Michael Worobey identified that early on into the pandemic — before the Huanan market was identified as a shared risk factor — there were still a disproportionate number of cases connected to the market.

For instance, an influential study published in January of 2020 that analyzed early SARS-CoV-2 cases found 66% of the 41 cases analyzed were linked to the Huanan market. Importantly, the patients in this study were enrolled according to clinical presentation not epidemiological information.

Even if one still wants to object on the basis that the early focus of public officials on the Huanan market may have still resulted in a possible bias of cases linked to the market being disproportionately transferred to Jinyintan Hospital where the study was conducted, they will also have to confront the association of cases from when hospitals had first pieced together that a new viral outbreak was underway:

• “Thus, 10 of these hospitals’ 19 earliest COVID-19 cases were linked to Huanan Market (∼53%), comparable both to Jinyintan’s 66% (of 41 cases) (4) and to the WHO-China report’s 33% of 168 retrospectively identified cases within Wuhan across December 2019 (1). Regarding cases at the Wuhan Central Hospital and HPHICWM, patients with a history of exposure at Huanan Market could not have been “cherry picked” before anyone had identified the market as an epidemiologic risk factor. Hence, there was a genuine preponderance of early COVID-19 cases associated with Huanan Market.”

It should also be stated that early cases are not the only piece of epidemiological data pointing towards the Huanan Wet Market. Initial excess deaths to pneumonia, a figure far less susceptible to the bias Chan brings up, also cluster in the portion of central Wuhan the Huanan Wet Market is located, and again only later do those excess deaths appear in the region of Wuhan the WIV is located.

Phylogenetic and epidemiological data on the early COVID-19 pandemic in Wuhan — The origins of SARS-CoV-2: A critical review

This section of the essay also this links to a criticism of Pekar et al 2022's approach to excluding certain intermediate lineage A-B SARS-CoV-2 genomes. Immediately, I had some reservations, in the criticism they mention that “the authors fail to define what an artifact of contamination is, and how they can be sure it is an artifact.”

However, in the section of Pekar et al referring to said contamination the point seems clearly defined. The artifacts of contamination would be the presence C/C or T/T in nucleotide positions 8782 and 28144, caused either by sample cross-contamination or data processing errors.

The means of artifact identification would be the presence of rare single nucleotide variations (SNV’s) within the supposed intermediate lineages that are shared with lineage A or lineage B viruses — often sequenced in the same laboratory — alongside recognition of low read depth at the relevant genomic sites.

Regardless, the criticisms presented relating to lack of consistent standards for low read depth exclusion and lack of unique SNV’s immediately flanking positions 8782 and 28144 seem like they could be compelling.

Unfortunately, I don’t have the necessary subject knowledge to fully identify whether all the objections within this specific critic are valid or not. I recommend looking into both the paper and the response (as well as Pekar et al’s supplemental material) and judging for yourself if you're curious.

Even assuming said criticisms to be accurate, I don’t think on its own it does much to bolster the case for a Lab Leak given everything else we’ve gone over.

ABSENCE OF EVIDENCE ≠ EVIDENCE OF ABSENCE

Chan goes on to identify the fact that the evidence currently in favor of a zoonotic spillover has some gaps and holes that leave it as an incomplete accounting of SARS-CoV-2’s origins:

• “Despite the intense search trained on the animal trade and people linked to the market, investigators have not reported finding any animals infected with SARS‑CoV‑2 that had not been infected by humans. Yet, infected animal sources and other connective pieces of evidence were found for the earlier SARS and MERS outbreaks as quickly as within a few days, despite the less advanced viral forensic technologies of two decades ago.”
• “Even though Wuhan is the home base of virus hunters with world-leading expertise in tracking novel SARS-like viruses, investigators have either failed to collect or report key evidence that would be expected if Covid-19 emerged from the wildlife trade. For example, investigators have not determined that the earliest known cases had exposure to intermediate host animals before falling ill. No antibody evidence shows that animal traders in Wuhan are regularly exposed to SARS-like viruses, as would be expected in such situations.”

While it’s true that the evidence at this point is not dispositive — missing certain key features such as the identification of the exact infected intermediate host carrying SARS-CoV-2, nor the natural viral reservoir from which it would have originated from — this isn’t necessarily the damning counter evidence it is presented as.

It took over a year to identify the intermediary hosts of MERS and 2 months to detect the first infected animals for SARS, not days as Chan falsely implies. The intermediate host suspected to exist for HCOV-HKU1 has yet to be found, and finding the natural reservoir from which SARS stemmed was a decade long endeavor.

No antibody evidence exists for animal traders because the research wasn’t done when it would have been feasible to gain that valuable data early into the virus’s spread, not because we did the investigations and found nothing from them. Doing so now would be unhelpful as the virus has spread so broadly, just observing antibodies in animal traders wouldn’t tell us anything.

Chan also ignores that if any evidence was suppressed, it was likely evidence in connection to the Wet Markets.

As Dr. Angela Rasmussen points out in this twitter thread, at the onset of the pandemic the market was closed and disinfected, with live animals being removed due to public health concerns.

Screenshot From Dr. Rasmussen’s Twitter Thread Discussing Chan’s Essay.

Those animals were unfortunately slaughtered without carcasses being frozen, preventing comprehensive sampling from occurring and making it more difficult to identify exactly what species of animal would have been the intermediate host.

At one point, it was even stated that there were no verified reports of live mammals being sold at the Huanan Wet Market only for indisputable evidence of their sale to emerge in June of 2021.

This is unlike what happened with SARS where markets were allowed to remain open for a while, in turn facilitating the ability for testing and the identification of infected civets.

The case of zoonotic spillover may not be completely conclusive, but the circumstantial evidence present for it is strong.

As was mentioned, early COVID-19 cases and excess deaths from pneumonia cluster around the Huanan wet market, with serological signals — blood serum-based measurements of a pathogen’s prevalence in a population — pointing in this same direction.

Multiple distinct lineages of SARS-CoV-2 were associated with the wet market, as would be expected if it were in fact the origination point.

Environmental samples with contamination of both viral RNA and animal DNA in the Huanan wet market stalls have been identified, including in one not associated with any known human infection.

In fact, 5 positive samples were discovered in a single stall that had been known to sell raccoon dogs, one of the animals suspected as a possible intermediate host for SARS-CoV-2. To be clear, these things don’t indisputably prove said animals were carriers of SARS-CoV-2 but they do point in the direction.

On top of all that, the market itself isn’t really the kind of location you would expect to be an amplifying event — given its low number of visitors relative to other locations in Wuhan including other markets and malls — as opposed to the epicenter of the pandemic in accordance with the presence of wildlife known to be susceptible to SARS-CoV-2.

Proponents of the lab leak theory, in contrast, present nothing more than anomaly hunting, accusations of a colossal coverup, gestures toward unsubstantiated possibilities, and speculation.

THOSE HARMED IN THE PROCESS

The pushing of narratives like the lab leak based on faulty premises does more than hamper the scientific process of investigating SARS-CoV-2’s origin, they actively harm the lives of actual people.

The same day Chan’s essay was published, Dr. Fauci spoke in front of a house sub-hearing and at one point discussed the multiple credible death threats he and his family received during his time as director of the National Institute for Allergy and Disease (NIAID):

• “Everything from harassments from emails, texts, letters of myself, my wife, my three daughters. There have been credible death threats leading to the arrest of two individuals — and credible death threats means someone who clearly was on their way to kill me. And it’s required my having protective services essentially all the time.”

Dr. Shi has also talked on several occasions about feelings of sorrow and frustration she has felt in the face of the accusations against her:

• “Not surprisingly, the allegations have taken a personal toll. “I’m a human being as well, you know,” Shi told me. “Have they considered what it feels like to be wrongly accused of unleashing a pandemic that has killed millions?””

It’s one thing to consider all possible venues by which the Covid-19 pandemic may have started, including possible lab leakage. This is an important and necessary process that should be engaged with seriously. Evidence strongly supporting a lab leak could come out and if it does we ought to realign our positions accordingly as honest interlocutors.

It’s another thing entirely to act as though said possibility is basically a foregone conclusion while presenting the barest bones of evidence to prove the point.

In a 2021 piece covering her role as a popular pro-lab leak figure, Chan was quoted as saying:

• “I have days where I think this could be natural. And if it’s natural, then I’ve done a terrible thing because I’ve put a lot of scientists in a very dangerous spot by saying that they could be the source of an accident that resulted in millions of people dying, I would feel terrible if it’s natural and I did all this.”

Regardless of what SARS-CoV-2’s origin ultimately ends up being, it’s time for Chan to consider that her having done a “terrible thing” may not just be possibly but in fact probably the case.

Editor’s Note: Earlier version of this article did not include details surrounding comments in an early draft of project DEFUSE that seemingly indicate that where certain aspects of FCS research — such as conducting binding assays — would take place were open to change.