Informed Consent Action Network

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The Informed Consent Action Network (ICAN) is a United States-based non-profit organization founded in 2016 by Del Bigtree to investigate the safety profiles of vaccines, pharmaceutical drugs, and medical procedures while promoting the principle of informed consent for individuals prior to undergoing such interventions.^[1]^[2] ICAN employs a strategy centered on Freedom of Information Act (FOIA) requests, legal petitions, and lawsuits against federal agencies including the Department of Health and Human Services (HHS), Centers for Disease Control and Prevention (CDC), and National Institutes of Health (NIH) to compel the release of safety data and documentation that regulators are required by law to maintain but often withhold from public scrutiny.^[1]^[3] Through these efforts, ICAN has secured court-ordered disclosures of previously unreleased datasets, such as the CDC's V-safe monitoring system reports on COVID-19 vaccine adverse events, revealing patterns of underreporting and health impacts that challenge official narratives on vaccine safety.^[4]^[1] The organization's activities extend to public education via resources like scientific analyses, legal updates, and media production, including Bigtree's platform The HighWire, which disseminates findings from obtained documents to highlight discrepancies between regulatory claims and empirical evidence on risks such as autoimmune disorders, neurological effects, and pregnancy outcomes associated with vaccines.^[5]^[6] Notable achievements include forcing HHS to concede the absence of comprehensive vaccine safety studies as mandated under the National Childhood Vaccine Injury Act of 1986, and recent petitions demanding transparency on updated COVID-19 vaccine approvals from manufacturers like Moderna and Novavax.^[1]^[7] While ICAN's data-driven advocacy has amplified calls for accountability amid rising vaccine injury reports and eroded public trust in health authorities—particularly following the rapid deployment of COVID-19 countermeasures without long-term safety trials—it has drawn opposition from pharmaceutical interests and public health establishments, which frequently characterize the group as oppositional to vaccination rather than focused on verifiable safety evidence.^[8]^[3] Funded primarily through donations, ICAN reported revenues exceeding $20 million in recent years, enabling sustained litigation and outreach to support affected individuals and policy reform.^[2]

Founding and History

Establishment and Early Development

The Informed Consent Action Network (ICAN) was established in 2016 as a non-profit organization by Del Bigtree, a television producer with prior experience on CBS daytime programs including The Doctors, for which he received an Emmy Award.^[5]^[9] Bigtree's involvement in vaccine-related issues began with his production of the 2016 documentary Vaxxed: From Cover-Up to Catastrophe, which centered on claims by CDC whistleblower William Thompson alleging omission of data linking the MMR vaccine to autism risk in certain populations.^[5]^[10] ICAN's founding was driven by Bigtree's assessment of deficiencies in vaccine safety protocols, including the lack of large-scale, placebo-controlled trials for many vaccines and inadequate long-term monitoring of adverse events post-licensure.^[5] The organization aimed to address these through demands for transparency in government-held data, rooted in the principle that individuals require verifiable evidence of safety and efficacy to exercise informed consent prior to medical procedures like vaccination.^[1] In its early phase, ICAN structured itself around legal advocacy to compel federal agencies such as the Department of Health and Human Services and the CDC to release raw safety data via mechanisms like Freedom of Information Act requests, positioning the group as a counter to perceived regulatory opacity rather than outright opposition to vaccines.^[1] This approach emphasized empirical scrutiny over policy mandates, with initial resources directed toward public education on data gaps rather than broad anti-vaccination campaigns.^[5]

Key Milestones and Expansion

In October 2017, ICAN dispatched a letter to the U.S. Department of Health and Human Services (HHS) seeking documentation of vaccine safety surveillance, specifically the biennial reports to Congress required under the 1986 National Childhood Vaccine Injury Act to assess adverse events and program efficacy.^[11] Following an initial FOIA request in August 2017 and subsequent litigation, HHS stipulated in a 2018 settlement that no such reports had been filed since the Act's enactment.^[12] ICAN's activities intensified during the COVID-19 pandemic from 2020 to 2023, with multiple FOIA requests targeting clinical trial data for emergency-use-authorized vaccines, including details on placebo controls and post-marketing safety surveillance.^[13]^[14] These pursuits, alongside petitions challenging vaccine labeling omissions, amplified ICAN's role in transparency advocacy amid heightened public scrutiny of regulatory processes.^[15] By 2025, ICAN broadened its regulatory engagements beyond vaccines, submitting a citizen petition to the FDA on October 6 urging revised labeling for acetaminophen products to highlight risks of neurodevelopmental disorders from prenatal exposure, supported by epidemiological studies associating prolonged use with elevated odds of autism spectrum disorder and ADHD in offspring.^[16] In September 2025, ICAN facilitated a Senate Permanent Subcommittee on Investigations hearing on vaccine safety science, spotlighting unpublished research on chronic illness disparities between vaccinated and unvaccinated populations to press for data release and peer review.^[17]^[18] These initiatives marked ICAN's evolution toward influencing broader pharmaceutical oversight and legislative inquiries.

Leadership and Organizational Structure

Del Bigtree's Role

Del Bigtree, an Emmy Award-winning television producer, transitioned from mainstream media to vaccine advocacy following his work on health segments for the CBS show The Doctors, where he produced a 2011 episode scrutinizing the safety of the Gardasil HPV vaccine, prompting his deeper examination of pharmaceutical influences on public health narratives.^[19] This experience fueled his skepticism toward regulatory assurances, leading him to produce the 2016 documentary Vaxxed: From Cover-Up to Catastrophe, which centered on claims by CDC scientist William Thompson that agency officials omitted data from a 2004 study suggesting a higher autism risk in African American boys receiving the MMR vaccine before 36 months of age.^[20] The film, directed by Andrew Wakefield, amplified these whistleblower allegations and positioned Bigtree as a prominent critic of vaccine development transparency.^[21] In 2016, Bigtree founded the Informed Consent Action Network (ICAN) and assumed the role of CEO, applying his production expertise to craft media strategies that emphasize data-driven challenges to vaccine safety claims through accessible formats like investigative reporting and visual storytelling.^[5] His leadership has integrated public education efforts, including hosting The Highwire, a weekly show that dissects regulatory documents and scientific studies to highlight potential oversight failures in vaccine and drug approval processes.^[3] This approach has established him as a leading voice in vaccine risk awareness, prioritizing empirical scrutiny of adverse event data over institutional endorsements.^[5] Bigtree's influence extends to alliances with figures advocating medical autonomy, notably serving as communications director for Robert F. Kennedy Jr.'s 2024 presidential campaign, where he shaped messaging against coercive vaccination policies.^[22] These ties have reinforced ICAN's focus on opposing mandates, framing them as infringements on individual consent amid revelations of regulatory inconsistencies, such as untested vaccine combinations in emergency authorizations.^[23] Through extensive public speaking at conferences and events, Bigtree continues to mobilize discourse on causal links between interventions and health outcomes, drawing from primary government records to underscore gaps in safety testing.^[24]

Governance and Key Personnel

The Informed Consent Action Network (ICAN) functions as a 501(c)(3) nonprofit organization, governed by an internal executive structure rather than a publicly detailed board of directors, with operations centered on a collaborative team of approximately 20 members specializing in advocacy, data review, and strategic actions.^[1] This framework prioritizes cross-functional coordination among scientists, researchers, and advocates to scrutinize public health data, contrasting with criticisms of opaque decision-making in agencies like the FDA and CDC, where internal processes have been revealed through ICAN's inquiries to lack comparable public accountability.^[1] ^[25] Key personnel include Chief Operating Officer Catharine Layton, who has managed legal coordination, media outreach, and fundraising since 2017, supported by her certificates in immunology and infectious disease from Harvard Medical School.^[26] Other operational roles encompass a Chief Innovation Officer for campaign development, a director of development for resource allocation, and specialized positions in research and journalism to facilitate evidence-based critiques of medical interventions.^[26] External legal support is provided by attorneys such as Aaron Siri of Siri & Glimstad LLP, who assists in Freedom of Information Act pursuits and related operational litigation, enabling the team's data-driven challenges without embedding counsel as permanent staff.^[27] ^[28] ICAN's governance model underscores transparency in resource use, directing 93% of funds toward programmatic activities like public education and data analysis, as self-reported in organizational disclosures—a practice positioned as a corrective to the non-disclosure norms observed in federal health bureaucracies.^[1] This structure fosters agility in responding to emerging safety concerns through iterative team reviews, rather than hierarchical mandates, aligning with the nonprofit's mandate for empirical accountability in consent processes.^[1]

Mission, Principles, and Focus Areas

The Informed Consent Action Network (ICAN) posits informed consent as an inviolable ethical and legal prerequisite for any medical intervention, emphasizing individuals' autonomy to refuse or accept procedures only after receiving exhaustive disclosure of potential risks, benefits, and alternatives. This principle derives from foundational medical ethics, including the patient's right to self-determination, and aligns with constitutional safeguards in the United States, such as protections against compelled bodily intrusions under the Fourth and Fourteenth Amendments. ICAN maintains that without such transparency, consent cannot be genuinely voluntary, positioning full disclosure as a bulwark against paternalistic overreach by medical authorities or government entities.^[1] Central to ICAN's advocacy is the contention that coercive policies, including those mandating participation in public health programs without opt-out provisions supported by rigorous safety evidence, erode the essence of voluntary choice. They argue these measures prioritize collective imperatives over personal agency, particularly when long-term causal effects remain unverified through independent, empirical scrutiny rather than reliance on institutional declarations. ICAN promotes a framework of causal accountability, insisting that health decisions must be informed by observable data on outcomes, not deferred to regulatory trust, to mitigate risks of unintended harm.^[1] In pursuing these objectives, ICAN seeks to empower patients and families by fostering a culture of skepticism toward unproven assurances, advocating instead for proactive verification of intervention safety profiles through accessible, unaltered evidence. This approach underscores their commitment to eradicating "man-made disease" via heightened accountability, ensuring that consent processes reflect reality-based risk assessment over procedural compliance.^[1]

Emphasis on Vaccine and Drug Safety

The Informed Consent Action Network prioritizes empirical evidence in assessing vaccine safety, contending that true safety cannot be established without randomized, placebo-controlled trials using inert placebos to isolate adverse events from background rates. ICAN has documented that no U.S.-licensed vaccines for infants and children underwent such trials prior to approval, with licensing instead based on comparisons to other vaccines or historical data lacking inert controls.^[29] In a 2018 response to ICAN's inquiry, the U.S. Department of Health and Human Services confirmed it possessed no placebo-controlled studies demonstrating the overall safety of the childhood vaccine schedule.^[12] ICAN argues this evidentiary gap undermines claims of comprehensive pre-licensure safety, as active comparators may mask reactogenicity shared across products. ICAN extends this scrutiny to specific vaccines, including COVID-19 shots, petitioning the Food and Drug Administration in June 2021 to acknowledge the absence of inert placebo arms in pivotal trials and to require such designs for future authorizations.^[13] For updated formulations, ICAN filed Freedom of Information Act requests in August 2025 demanding all underlying safety documents relied upon by the FDA for approvals of Moderna and Novavax boosters, highlighting incomplete public disclosure of reactogenicity and long-term data.^[7] Similarly, in March 2025, ICAN interrogated the safety profiles of licensed H5N1 bird flu vaccines, revealing limited trial data and unverified claims of efficacy against circulating strains.^[30] Post-licensure systems like the Vaccine Adverse Event Reporting System receive ICAN's criticism for relying on passive, voluntary reports that signal potential harms but cannot quantify incidence or causality without active follow-up. ICAN maintains that authorities' admissions of data deficiencies—such as the lack of large-scale, controlled studies isolating vaccine effects from confounders—expose overreliance on observational methods prone to bias.^[11] Beyond vaccines, ICAN investigates pharmaceutical safety, notably petitioning the FDA on September 22, 2025, to mandate pregnancy risk warnings on acetaminophen labels, citing over 30 studies associating prenatal exposure with elevated odds of autism, ADHD, and reproductive disorders in offspring.^[16] The petition references meta-analyses showing consistent dose-response patterns, arguing regulatory inaction ignores causal signals from longitudinal cohorts despite animal models demonstrating neurotoxicity.^[31] While the FDA and manufacturers assert insufficient evidence of direct causation, ICAN emphasizes the precautionary need for labeling to enable informed consent amid unresolved epidemiological debates.^[32]

Legal Strategies and Activities

Freedom of Information Act Pursuits

The Informed Consent Action Network (ICAN) has systematically utilized Freedom of Information Act (FOIA) requests to obtain raw vaccine safety data, clinical trial records, and adverse event reports from federal agencies including the Centers for Disease Control and Prevention (CDC), Food and Drug Administration (FDA), Department of Health and Human Services (HHS), and National Institutes of Health (NIH).^[6]^[3] These requests target empirical evidence underlying agency claims on vaccine safety, such as pre-licensure studies for specific populations or mechanisms of action.^[7] By compelling responses, ICAN aims to highlight absences in foundational data, prompting agencies to acknowledge evidentiary shortcomings without relying on litigation outcomes.^[6] A notable example involves influenza and Tdap vaccines recommended for pregnant women. In 2019, ICAN's FOIA request to the FDA revealed no records of clinical trials demonstrating the safety of influenza vaccines for this group, nor any licensing explicitly for pregnancy use; the agency confirmed reliance on off-label recommendations absent supporting U.S.-based trials.^[33] Similarly, requests to the CDC for data on DTaP vaccine safety, including placebo-controlled trials or studies refuting links to conditions like autism, yielded responses indicating no such records existed to substantiate certain agency assertions.^[34]^[35] For COVID-19 vaccines, ICAN submitted targeted FOIA requests in 2020 and 2021 for biodistribution studies and mRNA persistence data, exposing gaps in domestic testing records.^[14] Agencies often responded with "no records found" for claims like rapid clearance of vaccine-induced spike protein, as in a September 2025 CDC reply confirming the absence of supporting studies.^[36] ICAN also secured raw V-Safe data from the CDC, comprising self-reported health surveys from over 10 million COVID-19 vaccine recipients, enabling independent analysis of post-vaccination symptoms.^[4] In August 2025, ICAN requested all FDA documents underpinning approvals for updated Moderna and Novavax COVID-19 vaccines, underscoring ongoing pursuits for transparency in biodistribution and long-term safety metrics.^[7] These efforts have collectively documented over hundreds of such queries, systematically probing for verifiable empirical foundations in vaccine oversight.^[3]

Major Lawsuits and Petitions

In 2017, ICAN filed a lawsuit against the U.S. Department of Health and Human Services (HHS) under the National Childhood Vaccine Injury Act of 1986, which mandates biennial reports to Congress on improvements in vaccine safety monitoring. HHS conceded in court documents filed on July 9, 2018, that it had not produced or submitted any such reports for over 30 years, despite legal requirements to assess and report on vaccine injury prevention efforts. This admission highlighted gaps in federal oversight of potential causal relationships between vaccines and adverse health outcomes, as ICAN argued the absence of reports undermined claims of robust safety surveillance. In December 2020, ICAN initiated a federal lawsuit against YouTube (Google LLC) and Facebook (Meta Platforms, Inc.), alleging illegal censorship and First Amendment violations after the platforms terminated ICAN's accounts without prior warnings or strikes, citing content on vaccine risks during the COVID-19 pandemic.^[37] The suit sought restoration of the accounts and argued that the deplatforming suppressed discourse on intervention-related harms, including potential vaccine side effects, in coordination with government pressures.^[37] A federal appeals court dismissed the case in February 2022, ruling the platforms' actions fell under Section 230 protections, though ICAN maintained the decision overlooked evidence of viewpoint discrimination tied to public health narratives.^[38] ICAN pursued regulatory challenges against specific vaccine approvals, including a June 2021 lawsuit against the Food and Drug Administration (FDA) questioning the licensure of the hepatitis B vaccine, asserting that pre-licensure safety data failed to demonstrate risks beyond seven days post-vaccination and lacked adequate controls for long-term causal effects on infant health.^[39] In August 2022, ICAN petitioned the FDA under 21 C.F.R. § 10.30 to revoke or suspend approval of the IPOL inactivated polio vaccine, citing the absence of properly randomized, placebo-controlled trials to establish safety and efficacy, particularly regarding risks of vaccine-derived poliovirus and neurological outcomes.^[40] The petition emphasized empirical gaps in proving no causal harm from the vaccine's components, drawing on historical data showing polio incidence declines predating widespread vaccination.^[40] In October 2023, ICAN filed a lawsuit to invalidate key provisions of the Public Readiness and Emergency Preparedness (PREP) Act, targeting manufacturer immunity from liability for COVID-19 countermeasures and the Countermeasures Injury Compensation Program's limitations on due process and evidentiary standards for injury claims.^[41] A follow-up suit in April 2024 supported plaintiffs challenging the program's adequacy for vaccine-injured individuals, arguing it denied fair hearings and obscured causal attributions of adverse events like myocarditis.^[42] These actions collaborated with allies such as Children's Health Defense, focusing on restoring legal accountability for unproven intervention safety profiles.^[41] ICAN has also petitioned the FDA for enhanced drug warnings, such as a 2025 request to update acetaminophen labels citing studies linking prenatal exposure to neurodevelopmental risks, underscoring demands for transparency on causal mechanisms beyond acute effects.^[16]

Notable Legal Outcomes

In July 2018, the U.S. Department of Health and Human Services (HHS) stipulated in Informed Consent Action Network v. HHS that it possessed no records of submitting required biennial reports to Congress on vaccine injury compensation, vaccine supply, and improvements in vaccine safety pursuant to the National Childhood Vaccine Injury Act of 1986 (42 U.S.C. § 300aa-27).^[43] This admission followed ICAN's Freedom of Information Act (FOIA) request and subsequent lawsuit, confirming that HHS had not fulfilled statutory monitoring obligations for over 30 years despite collecting data on vaccine-related injuries. In September 2022, a federal court ordered the Centers for Disease Control and Prevention (CDC) to release comprehensive V-safe data encompassing over 137 million health entries from users reporting symptoms following COVID-19 vaccination.^[44] This outcome stemmed from ICAN's litigation compelling disclosure of the previously unreleased dataset, which included free-text entries later fully mandated for production in January 2024, totaling 7.8 million entries over 12 months.^[45] The released data highlighted underreported adverse events, such as systemic reactions in a significant portion of surveyed individuals, though CDC analyses maintained overall vaccine safety.^[44] In June 2021, the CDC conceded in response to ICAN's lawsuit that it could not produce studies supporting its public claim that vaccines do not cause autism in babies, revealing an absence of direct comparative research on the full childhood vaccine schedule versus unvaccinated populations.^[46] This outcome underscored gaps in evidentiary support for CDC assertions on vaccine safety endpoints, prompting scrutiny of Vaccine Safety Datalink (VSD) utilization, where ICAN's efforts exposed that certain datasets, including potential placebo-controlled trial records for vaccines like DTaP, had not been comprehensively analyzed or publicly detailed prior to compelled disclosures.^[47]

Funding and Financial Operations

Revenue Sources and Donors

The Informed Consent Action Network (ICAN) obtains nearly all its funding from private contributions, which accounted for $23,123,376 or 99.5% of its $23.2 million total revenue in fiscal year 2023, as detailed in IRS Form 990 filings.^[48] These contributions encompass one-time individual donations, recurring monthly pledges totaling over $6 million in 2022, and grants from aligned foundations, with merchandise sales contributing a minor $25,603 in the same period.^[8] ICAN discloses no revenue from government grants in its financial statements, preserving operational independence in its regulatory critiques, though it accepted a forgivable Paycheck Protection Program loan during the 2020 economic downturn.^[48]^[49] Major funding has historically included substantial support from foundations within vaccine-skeptic networks, such as the Selz Foundation, which provided approximately three-fourths of ICAN's budget in 2019.^[50] Many contributions route through donor-advised funds, a mechanism facilitating anonymous giving often utilized by high-net-worth individuals skeptical of mainstream vaccine policies.^[51] ICAN explicitly avoids pharmaceutical industry funding, consistent with its mission to challenge drug and vaccine safety oversight, and relies on public transparency via IRS-mandated disclosures rather than itemizing all donors, as Schedule B contributor details remain confidential for privacy.^[52]^[48] This donor composition underscores ICAN's dependence on grassroots and ideologically aligned private support, with no reported ties to corporate or institutional funders outside sympathetic advocacy circles.^[52]

Financial Growth and Transparency

The Informed Consent Action Network (ICAN) reported revenue of $23 million for the fiscal year ending December 2023, reflecting a 74% increase from $13.4 million in 2022.^[23] ^[8] This growth paralleled rising public interest in vaccine safety and informed consent issues amid ongoing debates over COVID-19 vaccine policies and mandates.^[23] Expenditures rose to nearly $17 million in 2023, a 25% increase from the prior year, with substantial allocations to legal activities, including $6 million directed to the law firm Siri & Glimstad for litigation support.^[23] In 2022, program services—encompassing legal pursuits, educational outreach, and advocacy—accounted for 93.6% of total expenses ($12.7 million out of $13.6 million), underscoring a focus on mission-driven operations over administrative overhead.^[8] CEO Del Bigtree received $234,000 in compensation in 2023, a figure disclosed in IRS Form 990 filings, which some critics argue warrants scrutiny relative to organizational impact, though proponents contend it reflects the demands of leading resource-intensive legal challenges.^[23] ICAN maintains financial accountability through public IRS Form 990 disclosures and annual Donor Impact Reports, which break down revenue streams and expense categories, achieving a 4/4 star rating from Charity Navigator for transparency and governance.^[53] ^[8] This approach stands in contrast to documented lapses in transparency by federal agencies like the Department of Health and Human Services, which ICAN has litigated against for incomplete vaccine adverse event reporting under statutory mandates.^[8]

Public Advocacy and Educational Efforts

Campaigns on Vaccine Transparency

In October 2017, the Informed Consent Action Network (ICAN) launched a public campaign challenging the U.S. Department of Health and Human Services (HHS) to provide documentation proving compliance with its statutory duty under 42 U.S.C. § 300aa-27 to annually report on improvements in vaccine safety since 1986.^[11] The initiative highlighted alleged gaps in federal vaccine monitoring, demanding empirical evidence of safety studies, including placebo-controlled trials for pediatric vaccines, which ICAN argued were absent or inadequately conducted.^[54] HHS's subsequent response in January 2019 asserted that safety had been verified through clinical trials and post-licensure surveillance but provided no supporting records or data voids addressing ICAN's specific queries on adverse event tracking and causation analysis.^[55] ICAN followed with a detailed refutation, publicly disseminating the correspondence to underscore the lack of verifiable proof for claims of comprehensive safety oversight, such as the absence of studies isolating vaccine ingredients' effects or long-term efficacy data against evolving pathogen strains.^[54] This effort extended to media amplification via platforms like The Highwire, where ICAN representatives critiqued federal assertions of robust monitoring systems like VAERS, citing underreporting rates estimated at less than 1% of serious events based on historical surveys.^[11] Complementing these advocacy letters, ICAN has released FOIA-obtained datasets to educational resources, including V-safe free-text entries from over 10 million COVID-19 vaccine recipients documenting symptoms like cardiac issues and neurological effects not reflected in aggregated CDC summaries.^[4] Similarly, disclosures of lot-specific data for vaccines like Johnson & Johnson revealed variability in reported adverse events, prompting campaigns questioning uniformity in manufacturing quality and risk profiles.^[14] In August 2025, ICAN reiterated these transparency demands by submitting FOIA requests for all raw safety documents underlying FDA approvals of updated Moderna and Novavax COVID-19 vaccines, arguing that partial releases obscured potential causal links to observed health declines.^[7]

Broader Public Engagement Initiatives

The Informed Consent Action Network maintains an online platform featuring educational resources aimed at empowering individuals to make autonomous health decisions, including white papers and summary charts on regulatory accountability and intervention safety.^[6] These materials emphasize scrutiny of environmental and pharmaceutical influences on well-being, extending beyond specific interventions to broader inquiries into food, air, water, and drug quality.^[2] ICAN produces multimedia content to foster public discourse on causal factors in health outcomes, such as the 2025 documentary An Inconvenient Study, which examines unpublished research on chronic disease links to early-life exposures and has prompted global discussions on evidence-based risk assessment.^[56]^[1] Complementing this, the organization's affiliated The HighWire internet talk show, hosted by founder Del Bigtree, reaches over 4.5 million viewers weekly across more than 190 countries, disseminating data-driven analyses to challenge institutional narratives that downplay potential adverse effects of health policies.^[5]^[1] Through these channels, ICAN promotes tools for personal agency, including downloadable presentations on exemption strategies and regulatory oversight, encouraging community-level evaluation of health authority claims against empirical records.^[6] This outreach prioritizes transparency in decision-making processes, positioning individuals as primary evaluators of multifaceted health risks rather than passive recipients of expert consensus.^[1]

Reception, Controversies, and Debates

Achievements and Supporter Perspectives

ICAN's legal efforts have compelled federal agencies to disclose the absence of certain vaccine safety studies, which supporters cite as empirical validations of oversight failures. In a July 9, 2018, stipulation resulting from ICAN's lawsuit against the U.S. Department of Health and Human Services (HHS), the agency admitted it had not produced or submitted any biennial reports to Congress on vaccine injury prevention or safety improvements since the 1986 National Childhood Vaccine Injury Act required them every two years.^[57] Proponents regard this concession as exposing a 30-year regulatory lapse in mandated safety monitoring, thereby enabling public examination of unverified assumptions underlying vaccine policies.^[8] Further disclosures obtained via ICAN's litigation include the Centers for Disease Control and Prevention's (CDC) March 2020 stipulated order acknowledging no existing studies assessing whether vaccines routinely given to infants in their first six months—such as DTaP, hepatitis B, Hib, PCV13, and IPV—do not cause autism.^[58] In 2020, the National Institutes of Health (NIH) similarly conceded a lack of studies on the safety of aluminum adjuvants in infant vaccines.^[8] Advocates interpret these admissions as concrete proof of evidentiary voids in foundational safety claims, facilitating informed decision-making by highlighting reliance on incomplete data rather than comprehensive trials.^[8] ICAN's Freedom of Information Act pursuits have also yielded raw datasets for independent review, including over 137 million health entries from the CDC's V-safe app monitoring COVID-19 vaccine recipients, released after multiple lawsuits and encompassing free-text reports of adverse events.^[4] Supporters praise this as a triumph in transparency, arguing it arms individuals with unfiltered evidence of post-vaccination experiences, countering opaque regulatory narratives and promoting accountability.^[8] From the perspective of ICAN's backers, these victories establish the organization as a defender of informed consent rights, using judicial mechanisms to unearth systemic deficiencies that erode trust in health authorities. They contend that such data-driven revelations justify skepticism toward consensus-driven endorsements, framing vaccine hesitancy as an evidence-based stance responsive to demonstrable gaps in verification processes.^[1]^[8]

Criticisms from Mainstream and Regulatory Bodies

Mainstream media outlets have accused the Informed Consent Action Network (ICAN) of functioning as an anti-vaccination organization that sows disinformation through aggressive legal campaigns, particularly by capitalizing on public fears over vaccine mandates to deter uptake.^[59] For instance, reporting in 2021 highlighted ICAN's series of lawsuits and petitions as efforts to undermine vaccination efforts amid the COVID-19 pandemic, framing such actions as part of a broader strategy to erode trust in regulatory approvals.^[59] These portrayals often equate ICAN's demands for transparency on vaccine safety data—such as placebo-controlled trials—with outright opposition to immunization, without directly addressing the empirical gaps in historical testing records that ICAN's inquiries have spotlighted.^[60] Legal scholars have critiqued ICAN's approach to Freedom of Information Act (FOIA) requests and litigation as a mechanism to spin false narratives, alleging that the organization misrepresents agency responses and court stipulations to imply systemic concealment of vaccine risks.^[60] A 2022 analysis in the Northwestern Journal of Law and Social Policy examined cases like ICAN's 2017 FOIA lawsuit against the Department of Health and Human Services (HHS), where a stipulation of dismissal was portrayed by ICAN as an admission of no vaccine safety monitoring efforts, despite prior agency reports documenting such activities.^[60] Similarly, in a 2019 FOIA suit against the Centers for Disease Control and Prevention (CDC) regarding studies on vaccines and autism, the CDC provided references to existing research, yet ICAN claimed this as evidence of absent data, a tactic described as reinforcing preconceived anti-vaccine beliefs rather than yielding verifiable new insights.^[60] Critics contend this pattern prioritizes in-group mobilization and talking points over substantive legal victories, contributing to vaccine hesitancy by amplifying distrust without empirical refutation of the queried data voids.^[60] Regulatory bodies such as the Food and Drug Administration (FDA) and CDC have countered ICAN's petitions and suits through denials and court defenses emphasizing established safety protocols, viewing the inquiries as attempts to challenge scientific consensus via procedural maneuvers.^[61] For example, the FDA rejected ICAN's 2020 citizen petition on the Moderna COVID-19 vaccine, asserting that the requested long-term placebo data was unnecessary given post-authorization surveillance systems like VAERS, which track adverse events without confirming causality in isolation.^[60] In related litigation, such as ICAN v. NIH (2020), agencies released datasets on vaccine trials but maintained that ICAN's interpretations ignored broader evidence from observational studies and meta-analyses, framing the disputes as distractions from proven risk-benefit profiles rather than genuine transparency deficits.^[62] These institutional responses often dismiss ICAN's focus on causal links—such as unaddressed potential for vaccine-induced conditions—as unfounded, prioritizing population-level efficacy data over individualized risk inquiries. Critiques have also targeted ICAN's financial ties to figures like Robert F. Kennedy Jr. and organizations such as Children's Health Defense (CHD), portraying these as conduits for anti-vaccine funding that amplify legal activism without rigorous scientific backing.^[23] Reporting in late 2024 noted ICAN's revenue surge to $23 million in 2023, attributing much of the growth to donors aligned with Kennedy's network, which mainstream sources link to promotion of unsubstantiated claims about vaccine harms.^[23] Such associations are cited as evidence of coordinated efforts to foster hesitancy, with detractors arguing that resources funneled through these channels support narrative-driven lawsuits over evidence-based public health advocacy, though the funding enables FOIA successes revealing regulatory admissions of data limitations.^[63]

Ties to Broader Movements

The Informed Consent Action Network (ICAN) maintains alliances with key figures and organizations in the vaccine transparency and health policy reform movements, including attorney Aaron Siri and Robert F. Kennedy Jr. (RFK Jr.). Siri, through his firm Siri & Glimstad LLP, has represented ICAN in numerous Freedom of Information Act (FOIA) lawsuits and regulatory petitions since at least 2017, securing disclosures of vaccine safety data from federal agencies.^[18]^[64] These efforts align with Siri's advisory role to RFK Jr. on health policy, including petitions filed on ICAN's behalf, such as a 2022 request to the FDA to revoke approval of the oral polio vaccine due to alleged safety risks.^[65]^[66] ICAN's executive director, Del Bigtree, has collaborated with RFK Jr.-led initiatives, including public calls in August 2025 for reforms to curb pharmaceutical industry influence on the CDC's Advisory Committee on Immunization Practices (ACIP).^[67] This partnership extends to overlaps with the "Make America Healthy Again" (MAHA) agenda, where ICAN's transparency goals intersect with RFK Jr.'s focus on chronic disease prevention and regulatory overhaul following his 2025 appointment as HHS Secretary.^[68] ICAN also operates within a network including Children's Health Defense (CHD), RFK Jr.'s former organization, sharing objectives in challenging vaccine mandates through litigation and advocacy, as seen in coordinated resistance to school requirements during the COVID-19 era.^[27] These ties have amplified ICAN's legal and empirical challenges to vaccine policies but sparked debates over potential conflicts, particularly regarding litigation funding and policy influence. Critics, including mainstream outlets, highlight ethical concerns about Siri's dual roles in suing regulators while advising HHS, potentially blurring lines between advocacy and governance.^[69] Proponents argue such collaborations prioritize data-driven accountability over institutional deference, countering claims of bias by emphasizing verifiable FOIA outcomes rather than partisan narratives.^[70] Mainstream characterizations often frame these networks as "anti-vaccine," though ICAN's work centers on consent and disclosure mandates, not outright opposition.^[23]

Impact on Policy and Public Discourse

Influences on Government Accountability

In 2018, the Informed Consent Action Network (ICAN) filed a lawsuit against the U.S. Department of Health and Human Services (HHS) under the Freedom of Information Act, seeking biennial reports mandated by the National Childhood Vaccine Injury Act of 1986 (42 U.S.C. § 300aa-27), which required HHS to submit evidence to Congress on improvements in vaccine safety surveillance and injury compensation. HHS conceded in a July 9, 2018, court filing that no such reports had been produced or submitted since the law's enactment, admitting a failure to meet statutory accountability obligations spanning over three decades.^[71] This disclosure prompted congressional inquiries and public scrutiny of federal vaccine monitoring gaps, including subsequent demands for internal HHS reviews of adverse event reporting systems like VAERS, though HHS maintained that safety efforts continued through other channels.^[72] ICAN's FOIA litigation against the Centers for Disease Control and Prevention (CDC) yielded significant data releases, such as the 2022 court-ordered disclosure of V-safe app entries encompassing over 137 million health surveys from COVID-19 vaccine recipients, revealing patterns of reported adverse events including hospitalizations and life-threatening conditions that had not been proactively analyzed or publicized by the agency.^[44] Similarly, suits against the National Institutes of Health (NIH) compelled revisions to redacted COVID-19 vaccine trial documents, exposing limitations in preclinical biodistribution studies where lipid nanoparticles were shown to accumulate in organs like the liver, ovaries, and spleen rather than remaining localized at injection sites—data not fully detailed in initial regulatory approvals.^[62] These outcomes pressured CDC and NIH to acknowledge surveillance shortcomings, including the absence of long-term placebo-controlled trials for certain vaccine safety claims, fostering demands for enhanced causal tracking of potential adverse outcomes beyond immediate post-vaccination periods.^[34] ICAN's petitions to the Food and Drug Administration (FDA) have influenced ongoing debates over vaccine labeling and approval transparency, such as 2021-2022 requests for records supporting claims that COVID-19 vaccines do not alter DNA or interact with genetic material, which highlighted regulatory reliance on manufacturer-submitted data without independent verification of key mechanisms like reverse transcription risks.^[73] In 2025, ICAN's FOIA demands for full safety dossiers on updated Moderna and Novavax COVID-19 vaccines underscored gaps in pregnancy-related testing and biodistribution modeling, contributing to FDA reconsiderations of warning labels and post-market surveillance protocols to better reflect empirical risks over assumptive safety profiles.^[7] These efforts have causally linked advocacy to procedural shifts, including accelerated data unredactions and petitions prompting FDA acknowledgments of incomplete pre-approval datasets, thereby elevating requirements for verifiable evidence in regulatory decision-making.

Effects on Vaccine Policy and Awareness

ICAN's advocacy has influenced discussions on vaccine mandates, particularly by underscoring gaps in informed consent processes during policy formulations for school requirements and COVID-19 responses. For instance, in 2021 Texas legislative hearings on vaccine mandates, witnesses emphasized personal rights and consent voids, contributing to debates that questioned blanket enforcement without robust safety data transparency.^[74] ICAN supported such discourse through educational materials, including a September 2024 presentation detailing state-specific childhood vaccine mandates and exemption strategies, which aimed to empower individuals against perceived overreach.^[75] The organization has heightened public awareness of limitations in vaccine adverse event surveillance, notably underreporting in VAERS. In April 2021, ICAN corresponded with CDC's Immunization Safety Office, citing empirical evidence that serious injuries from vaccines, including COVID-19 shots, were significantly underreported—potentially by factors exceeding 10-fold based on prior studies like the 2010 Harvard Pilgrim analysis.^[76] ^[77] This push challenged prevailing media and regulatory assurances of comprehensive monitoring, prompting calls for mandatory reporting protocols and independent validation of safety claims, as VAERS relies on voluntary submissions prone to incomplete capture.^[78] Federal reviews, such as those by the Institute of Medicine, have corroborated VAERS's inherent under-detection of events, estimating it signals only a fraction of occurrences.^[79] Over time, ICAN's efforts have spurred broader empirical scrutiny of vaccine policies, framing vaccine hesitancy not as irrational but as a rational response to evidentiary shortfalls in long-term safety data. By disseminating analyses via platforms like The Highwire, ICAN has amplified demands for reformed pharmacovigilance, including proactive government studies on cumulative effects, potentially influencing future policy toward enhanced pre-mandate consent mechanisms and decentralized research.^[3] This has coincided with observed rises in public demand for transparency amid COVID-19 rollout debates, where initial policy rigidities faced pushback linked to unverified risk-benefit assertions.^[11]

References

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About Us - ICAN - Informed Consent Action Network
Founded in 2016, ICAN was created with the goal of providing every person with the right to informed consent.
[2]
Informed Consent Action Network - GuideStar Profile
Mission. INVESTIGATING THE SAFETY OF MEDICAL PROCEDURES, PHARMACEUTICAL DRUGS, AND VACCINES WHILE ADVOCATING FOR A PERSON'S RIGHT TO "INFORMED CONSENT".Missing: founding | Show results with:founding
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[PDF] Informed Consent Action Network - Supreme Court
Feb 5, 2024 · ICAN has been instrumental in demanding accountability for government narratives regarding vaccines and drugs through various successful.<|separator|>
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V-Safe Data - ICAN - Informed Consent Action Network
Find the interactive V-Safe dashboards below and click the DOWNLOAD buttons to obtain exclusive data obtained by ICAN.
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Del Bigtree - ICAN - Informed Consent Action Network
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Use the filter to search ICAN's library of lawsuits, FOIA's, legal letters, scientific and educational resources
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[PDF] Donor Impact Report 2023 - Informed Consent Action Network
Founded in 2016, ICAN was created to educate all individuals on their right to informed consent. We believe that by holding.
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I am proud to report that data show the United States currently has the safest supply in history. I have provided responses to your specific questions in ...
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[PDF] Who Is Del?
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[PDF] NO Placebo
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ICAN Attorneys Demand Answers on Bird Flu Vaccines
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[PDF] Page 1 of 42 October 17, 2025 By Electronic Submission ... - Kenvue
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[PDF] CDC Concedes in Federal Court It Does Not Have Studies to ...
Mar 5, 2020 · The FDA, pursuant to a FOIA request from ICAN, eventually produced the clinical trials it relied upon to license the current MMR vaccine which ...
[35]
[PDF] Research and Findings on Efficacy of DTP
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[36]
Segment 3: CDC Unable to Support Claim that COVID-19 Vaccine ...
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[38]
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WHEREAS, on June 27, 2018, HHS sent ICAN the following response to the FOIA. Request: The [Department]'s searches for records did not locate any records.
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Rating 4/4 · Review by Charity Navigator350k donors have given $300M+ to charities via Charity Navigator. Donate easily, safely, and even anonymously today!
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[PDF] 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 ...
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UNDERREPORTING OF SERIOUS INJURIES TO VAERS ...
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VAERS, LLDB, vaccine manufacturer surveillance measures, and FDA response procedures have several limitations. Speakers and participants voiced several ...