Kevin, Thanks for pointing this out to the AoIR list. Both Michael Zimmer and I have presented to the Secretary's Advisory Committee to OHRP, in our case on Internet research, and to date, OHRP has not issued any specific guidance on Internet research. Interestingly, too, the FDA withdrew Internet research as an item from its 2011 Guidance Agenda. For those wanting to understand the process--note that this is "advance notice" only, and must go through a long process of comment and codification before any changes would be enacted--Zek Emanuel recently came out with this: http://healthpolicyandreform.nejm.org/?p=14979&query=home All best, e. Elizabeth A. Buchanan, Ph.D. Endowed Chair in Ethics Director, Center for Applied Ethics University of Wisconsin-Stout PO Box 790 Menomonie, Wisconsin, 54751-0790 buchanane@uwstout.edu