Category: 3. Business

  • Dynavax to Be Acquired by Sanofi for $2.2 Billion // Cooley // Global Law Firm

    Dynavax to Be Acquired by Sanofi for $2.2 Billion // Cooley // Global Law Firm

    New York – December 24, 2025 – Cooley advised Dynavax Technologies, a publicly traded vaccines company with a marketed adult hepatitis B vaccine (HEPLISAV-B), a shingles vaccine candidate and a differentiated clinical-stage pipeline, on its definitive agreement to be acquired by Sanofi for $15.50 per share in cash, representing an equity value of $2.2 billion. The acquisition strengthens Sanofi’s position in adult immunization by bringing together Dynavax’s adult hepatitis B vaccine and promising shingles asset with Sanofi’s global scale, development capabilities and commercial reach.

    Lawyers Bill Roegge, Barbara Borden, Steve Przesmicki, Barbara Mirza, Austin Holt, David Burns and Jane Adams led the Cooley team advising Dynavax.

    Cooley previously advised Dynavax on its successful proxy contest in June 2025, its $225 million convertible notes offering in March 2025 and its $100 million accelerated share repurchase program in November 2024.

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  • Derivatives, Legislative and Regulatory Weekly Update (December 24, 2025)

    Derivatives, Legislative and Regulatory Weekly Update (December 24, 2025)

    Client Alert  |  December 24, 2025


    From the Derivatives Practice Group: This week, Michael S. Selig was sworn in as the 16th Chairman of the CFTC.

    Please note that there will be no newsletter next week as we pause for the holidays. Happy holidays to all!

    New Developments

    Michael Selig Sworn In as 16th CFTC Chairman. On December 22, Michael S. Selig was sworn in to serve as the 16th Chairman of the Commodity Futures Trading Commission. Chairman Selig was nominated by President Donald J. Trump to the post on October 27, 2025, and confirmed by the U.S. Senate on December 18, 2025. Chairman Selig most recently served as chief counsel of the Securities and Exchange Commission’s Crypto Task Force and senior advisor to SEC Chairman Paul S. Atkins. He also participated in the President’s Working Group on Digital Asset Markets and contributed to its report on “Strengthening American Leadership in Digital Financial Technology.” Chairman Selig earned his law degree from The George Washington University Law School and received his undergraduate degree from Florida State University. [NEW]

    Acting Chairman Caroline D. Pham Departs CFTC. On December 22, CFTC Acting Chairman Caroline D. Pham announced her departure from public service. Her last day at the CFTC was December 22, 2025. [NEW]

    Acting Chairman Pham Announced New Member of Global Markets Advisory Committee’s Digital Asset Markets Subcommittee. On December 22, CFTC Acting Chairman Pham announced Rob Hadick of Dragonfly Capital Partners joined the CFTC’s Global Markets Advisory Committee’s Digital Asset Markets Subcommittee. According to the CFTC, Hadick is a General Partner at Dragonfly Capital Partners, where he focuses on digital asset investment strategy, market structure innovation, and expanding global market opportunities across blockchain-based financial systems. [NEW]

    Acting Chairman Pham Announced Pilot Program to “Unleash American Energy Dominance.” On December 19, CFTC Acting Chairman Pham announced that the Market Participants Division (MPD) established a pilot program designed to increase liquidity and hedging of risks in connection with Energy Commodity End User Swaps. Specifically, MPD staff issued a no-action letter that provides for a pilot program that will exclude certain Energy Commodity End User Swaps from the swap dealer de minimis calculation. Participants in the pilot program are required to submit monthly reports on energy commodity sub-category, aggregate notional value and number of counterparties for CFTC market oversight. [NEW]

    CFTC Staff Issues No-Action Letter Regarding CPO Registration for Certain SEC-Registered Investment Advisers. On December 19, MPD announced it had issued a no-action letter in response to a request submitted by the Managed Funds Association on behalf of its members. The letter states MPD will not recommend the CFTC initiate an enforcement action against firms registered as investment advisers with the Securities and Exchange Commission that operate commodity pools privately offered solely to sophisticated investors known as qualified eligible persons for failing to register with the CFTC as a commodity pool operator, subject to certain conditions. [NEW]

    CFTC Approves Final Rule to Revise Swap Dealer Business Conduct and Swap Documentation Requirements. On December 18, the CFTC announced it has approved a final rule that codifies existing staff no-action positions for certain of the CFTC’s business conduct and documentation requirements applicable to swap dealers and major swap participants. The final rule amendments further harmonize the CFTC’s rules with those of the Securities and Exchange Commission and the Municipal Securities Rulemaking Board.

    CFTC Staff Seek Public Comment on Direct Clearing by Retail Participants. On December 18, the CFTC issued a Request for Comment to better inform the staff’s understanding of the issues related to derivatives clearing organizations that provide direct clearing services to retail traders. These clearing services may be provided either through a fully-collateralized clearing model that has direct access for retail participants, or a hybrid model that includes both fully-collateralized direct clearing to retail participants and intermediated clearing by futures commission merchants to retail customers.

    Acting Chairman Pham Announced Implementation of U.S. Treasury Market Reforms. On December 12, CFTC Acting Chaiman Pham announced the CFTC had approved a proposed order to grant a limited exemption necessary for the Chicago Mercantile Exchange Inc. and the Fixed Income Clearing Corporation to make their existing cross-margining arrangement available to certain customers with appropriate safeguards.

    CFTC Staff Issues No-Action Letters Regarding Event Contracts. On December 11, the CFTC’s Division of Market Oversight and Division of Clearing and Risk announced they have taken a no-action position regarding swap data reporting and recordkeeping regulations in response to requests from multiple registered entities, including designated contract markets and derivatives clearing organizations. According to the announcement, the Divisions will not recommend the CFTC initiate an enforcement action against certain registered entities or their participants for failure to comply with certain swap-related recordkeeping requirements and for failure to report to swap data repositories data associated with binary option transactions executed on or subject to the rules of the registered entities, subject to the terms of the no-action letters.

    CFTC Staff Issues No-Action Position Relating to Designated Contract Market Procedures. On December 11, the CFTC’s Division of Market Oversight announced it has issued a no-action letter to Small Exchange Inc., a designated contract market, which addresses certain procedures related to dormancy. The no-action position is time-limited and subject to the terms and conditions in the Division’s no-action letter.

    Acting Chairman Pham Announced Withdrawal of “Outdated” Digital Assets Guidance. On December 11, CFTC Acting Chairman Pham announced that the CFTC will withdraw “outdated” guidance related to actual delivery of “virtual currencies,” given the substantial developments in crypto asset markets. The CFTC said that the withdrawal of the guidance will enable the CFTC to continue its ongoing work to implement the recommendations in the President’s Working Group on Digital Asset Markets report.

    CFTC Staff Issues No-Action Letter Regarding Part 43 and Part 45 Requirements. On December 11, the CFTC’s Division of Market Oversight took a no-action position in response to a request from the International Swaps and Derivatives Association regarding certain data requirements under Part 43 and Part 45 of the CFTC’s regulations to reduce unnecessary and excessive regulatory burden and associated costs.

    Acting Chairman Pham Announced CEO Innovation Council Participants. On December 10, CFTC Acting Chairman Pham announced the first round of CEO Innovation Council participants, representing exchanges. The CFTC said that the CEO Innovation Council will engage in public discussion of market structure developments in derivatives markets and that further information on the CEO Innovation Council will be released once details are finalized.

    Acting Chairman Pham Announced Regulatory Clarity for U.S. Access to Markets. On December 9, CFTC Acting Chairman Pham announced that the CFTC’s Market Participants Division, Division of Clearing and Risk, and Division of Market Oversight issued a no-action letter to harmonize three separate definitions of “U.S. person,” among other things, under the CFTC’s Dodd-Frank Act cross-border swap framework. According to the CFTC, the letter simplified and consolidated existing no-action positions that address almost 15 years of regulatory uncertainty and promotes harmonization with SEC regulations.

    CFTC to Accelerate Publication of Backlogged COT Data. On December 9, the CFTC announced that it is accelerating the publication of Commitments of Traders reports that were interrupted during the lapse in federal appropriation. According to the CFTC, the revised timeline will eliminate the report backlog by December 29, 2025.

    Acting Chairman Pham Announced Launch of Digital Assets Pilot Program for Tokenized Collateral in Derivatives Markets. On December 8, CFTC Chairman Pham announced the launch of a digital assets pilot program for certain digital assets, including BTC, ETH, and USDC, to be used as collateral in derivatives markets; guidance on tokenized collateral; and withdrawal of outdated requirements given the enactment of the GENIUS Act. The CFTC said that the announcement follows the tokenized collateral initiative Acting Chairman Pham launched in September as a part of the CFTC’s Crypto Sprint to implement recommendations in the President’s Working Group on Digital Asset Markets report.

    New Developments Outside the U.S.

    ESMA Selects EuroCTP to Become the First Consolidated Tape Provider for Shares and ETFs. On December 19, ESMA selected EuroCTP as the first Consolidated Tape Provider for shares and exchange-traded funds in the EU, in a step forward for the transparency of equity markets in the EU. ESMA has decided to select EuroCTP following an in-depth assessment of its offer against the criteria listed in the Markets in Financial Instruments Regulation. EuroCTP has met all the selection criteria and has demonstrated a solid approach towards ESMA’s overall expectations for the award criteria.

    ESMA Reviews Impact of Guidelines on ESG or Sustainability Related Terms in Fund Names. On December 17, ESMA released research assessing the impact of its fund naming guidelines on ESG and sustainability-related terms. The study found that ESMA’s Guidelines have: (1) improved consistency in the use of ESG terms by increasing alignment of fund names and their actual investment strategies, and (2) enhanced investor protection by reducing greenwashing risks.

    ESMA Maintains Recognition of Two UK Central Counterparties under EMIR. On December 16, ESMA confirmed it will maintain the recognition of LCH Limited and LME Clear Limited, two central counterparties established in the United Kingdom. This decision is taken under Article 25(5)(b) of the European Market Infrastructure Regulation (EMIR), that requires ESMA to assess if the conditions under which LCH Limited and LME Clear Limited were originally recognized continue to be met, considering recent regulatory, market, and business developments.

    ESAs Publish Key Tips to Help Consumers Detect, Prevent, and Act on Online Frauds and Scams. On December 15, the three European Supervisory Authorities (ESAs) published two factsheets designed to help consumers protect themselves from crypto and other online frauds and scams and explain how fraudsters increasingly use artificial intelligence to deceive consumers. The factsheets provide practical tips to help consumers recognise and avoid different types of frauds and scams. Additionally, the factsheets advise consumers on steps to prevent fraud and scams, such as never sharing personal or banking information, always pausing to think before acting, and verifying the source of any messages received.

    ESMA Finalizes Technical Standards on Derivatives Transparency and the OTC Derivatives Tape. On December 15, ESMA published the Final Report covering mandates under the MiFIR Review on derivatives trade transparency, package orders and the over-the-counter (OTC) derivatives consolidated tape input and output data. The proposed pre- and post-trade transparency requirements for exchange traded derivatives and OTC derivatives are designed to provide a high level of transparency whilst ensuring that liquidity providers are protected from undue risk.

    ESMA Appoints Marie-Anne Barbat-Layani and Christopher P. Buttigieg as the New Members of its Management Board and Renews Armi Taipale’s Mandate. On December 11, ESMA appointed Marie-Anne Barbat-Layani of Autorité Des Marchés Financiers (France) and Christopher P. Buttigieg of Financial Services Authority (Malta), as the new members of its Management Board. The Board of Supervisors has reappointed Armi Taipale of Finanssivalvonta (Finland), for a second mandate.

    ESMA Chair Verena Ross to Step Down at the End of Her Current Term. On December 10, ESMA announced that its Chair, Verena Ross, has decided to not renew her term as Chair for a second mandate. According to ESMA, she will continue her work as ESMA’s Chair until the end of her contract on October 31, 2026. ESMA said that it will now launch the process for selecting a new Chair.

    ESMA Announces Supervisory Expectations for the Management Body in the Form of 12 High Level Principles. On December 10, ESMA published its Final Report on the Supervisory Expectations for the Management Body, outlining ESMA’s expectations for the management bodies of the entities under its supervision. ESMA said that the 12 high-level principles are directed at entities supervised by ESMA and those looking to obtain an ESMA license, and are designed to set out ESMA’s core expectations in the form of outcomes.

    New Industry-Led Developments

    ISDA Publishes Report on Interest Rate Derivatives Trading Activity Reported in EU, UK and US Markets. On December 16, ISDA published a report that analyzes interest rate derivatives (IRD) trading activity reported in Europe. The analysis is based on transactions publicly reported by 30 European approved publication arrangements (APAs) and trading venues (TVs). Key highlights for the third quarter of 2025 include: (1) European IRD traded notional reported by APAs and TVs in the EU and UK rose by 29.1% to $83.9 trillion in the third quarter of 2025 versus $65.0 trillion in the third quarter of 2024, and (2) Euro-denominated IRD traded notional fell by 5.9% to $33.1 trillion from $35.2 trillion, representing 39.5% of total European IRD traded notional.

    ISDA Responds to ASIC Consultation on Derivatives Transaction Rules. On December 16,  ISDA submitted a response to the Australian Securities and Investments Commission (ASIC) consultation on the remake of the ASIC Derivative Transaction Rules 2015, which are due to sunset on April 1, 2026. ASIC proposed to remake the rules in substantially the same form to continue the operation of Australia’s over-the-counter derivatives central clearing regime. Besides limited, minor and administrative amendments, ASIC proposed a policy update in the Draft ASIC Derivative Transaction Rules 2026 to extend exemptive relief to clearing derivatives transactions resulting from post-trade risk reduction exercises.

    Global Standard-Setting Bodies Publish Assessment of Margin Requirements for Non-Centrally Cleared Derivatives. On December 12, the Basel Committee on Banking Supervision (BCBS) and the International Organization of Securities Commissions (IOSCO) published a report that reviews the implementation of margin requirements for non-centrally cleared derivatives. IOSCO said the report concluded that the framework has been effectively implemented and finds no evidence of material issues. The BCBS-IOSCO Working Group on Margining Requirements recommended ongoing monitoring through supervisory information exchange and the sharing of experiences among member authorities.


    The following Gibson Dunn attorneys assisted in preparing this update: Jeffrey Steiner, Adam Lapidus, Marc Aaron Takagaki, Hayden McGovern, Karin Thrasher, and Alice Wang*.

    Gibson Dunn’s lawyers are available to assist in addressing any questions you may have regarding these developments. Please contact the Gibson Dunn lawyer with whom you usually work, any member of the firm’s Derivatives practice group, or the following practice leaders and authors:

    Jeffrey L. Steiner, Washington, D.C. (202.887.3632, jsteiner@gibsondunn.com)

    Michael D. Bopp, Washington, D.C. (202.955.8256, mbopp@gibsondunn.com)

    Michelle M. Kirschner, London (+44 (0)20 7071.4212, mkirschner@gibsondunn.com)

    Darius Mehraban, New York (212.351.2428, dmehraban@gibsondunn.com)

    Jason J. Cabral, New York (212.351.6267, jcabral@gibsondunn.com)

    Adam Lapidus, New York (212.351.3869,  alapidus@gibsondunn.com )

    Stephanie L. Brooker, Washington, D.C. (202.887.3502, sbrooker@gibsondunn.com)

    William R. Hallatt, Hong Kong (+852 2214 3836, whallatt@gibsondunn.com )

    David P. Burns, Washington, D.C. (202.887.3786, dburns@gibsondunn.com)

    Marc Aaron Takagaki, New York (212.351.4028, mtakagaki@gibsondunn.com )

    Hayden K. McGovern, Dallas (214.698.3142, hmcgovern@gibsondunn.com)

    Karin Thrasher, Washington, D.C. (202.887.3712, kthrasher@gibsondunn.com)

    Alice Yiqian Wang, Washington, D.C. (202.777.9587, awang@gibsondunn.com)

    *Alice Wang, a law clerk in the firm’s Washington, D.C. office, is not admitted to practice law.

    © 2025 Gibson, Dunn & Crutcher LLP.  All rights reserved.  For contact and other information, please visit us at www.gibsondunn.com.

    Attorney Advertising: These materials were prepared for general informational purposes only based on information available at the time of publication and are not intended as, do not constitute, and should not be relied upon as, legal advice or a legal opinion on any specific facts or circumstances. Gibson Dunn (and its affiliates, attorneys, and employees) shall not have any liability in connection with any use of these materials.  The sharing of these materials does not establish an attorney-client relationship with the recipient and should not be relied upon as an alternative for advice from qualified counsel.  Please note that facts and circumstances may vary, and prior results do not guarantee a similar outcome.

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  • In Corporate Counsel, Health Care Partners Examine Survey Results on Value of AI for Regulatory Monitoring | News & Events

    In Corporate Counsel, Health Care Partners Examine Survey Results on Value of AI for Regulatory Monitoring | News & Events

    In a Corporate Counsel and Law.com article, health care partners Ben Wilson, Christine Moundas and Michael Lampert examined the results of an AI adoption and governance survey conducted by Ropes & Gray and Corporate Counsel.

    The study results found that regulatory compliance is a top concern whether in-house counsel are considering present or future AI adoption, but that there is momentum building around AI adoption in the health care and life sciences industry.

    In the highly regulated health care sector, 61 percent of the in-house counsel surveyed said that monitoring current and emerging AI laws and regulatory actions is one of the actions taken by their organizations to manage AI legal, compliance and security risks.

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  • Gold Prices Reach Record Highs Amid Global Economic Uncertainty

    Gold Prices Reach Record Highs Amid Global Economic Uncertainty

    Gold prices soar to unprecedented levels, influenced by US Federal Reserve policies and rising geopolitical tensions across the globe.

    Gold prices have surged to new all-time highs in both domestic and international markets, driven by anticipation of further monetary easing by the United States Federal Reserve and increasing geopolitical tensions that have amplified the demand for safe-haven assets. In the domestic futures market, gold prices reached a lifetime peak of Rs1,38,676 per 10 grams on the Multi Commodity Exchange (MCX) on Wednesday. Gold futures for February delivery increased by Rs791, or 0.57%, marking the third consecutive session of gains for the precious metal.

    In global markets, Comex gold futures advanced for the fourth consecutive session, rising by $49.40, or 1.10%, to a record high of $4,555.10 per ounce. Jigar Trivedi, Senior Research Analyst at Reliance Securities, commented, “Gold surged past $4,500 per ounce to a fresh record, driven by expectations of further Federal Reserve easing and rising geopolitical tensions. Investors are still pricing in two rate cuts in 2026 as inflation cools and employment conditions soften, even as policymakers remain divided. Meanwhile, tensions between the US and Venezuela have been rising, which has lifted safe-haven demand and increased geopolitical risks across commodity markets.”

    City-wise gold prices in India have also reflected these trends:

    In Delhi, 22 carat gold is priced at Rs12,750 per gram, up by Rs35, while 24 carat gold stands at Rs13,908 per gram, increasing by Rs38. The price for 18 carat gold is Rs10,435 per gram, gaining Rs29.

    In Mumbai, 22 carat gold is available at Rs12,735 per gram, also up by Rs35, while 24 carat gold is at Rs13,893 per gram, rising by Rs38. The 18 carat variant is priced at Rs10,420 per gram, higher by Rs29.

    Bengaluru sees 22 carat gold at Rs12,735 per gram, matching the increase of Rs35, with 24 carat gold at Rs13,893 per gram, up by Rs38. The 18 carat gold rate is Rs10,420 per gram, also up by Rs29.

    In Hyderabad, the price for 22 carat gold is Rs12,735 per gram, up Rs35, while 24 carat gold stands at Rs13,893 per gram, gaining ₹38. The 18 carat gold rate is Rs10,420 per gram, increasing by Rs29.

    Chennai has reported 22 carat gold at Rs12,800 per gram, a rise of Rs30, with 24 carat gold priced at Rs13,964 per gram, up by Rs33. The 18 carat gold rate is Rs10,675 per gram, gaining Rs25.

    In Ahmedabad, the price for 22 carat gold is Rs12,740 per gram, up by Rs35, while 24 carat gold stands at Rs13,898 per gram, increasing by Rs38. The 18 carat gold rate is Rs10,425 per gram, up by Rs29.

    Jaipur witnesses 22 carat gold priced at Rs12,750 per gram, gaining Rs35, while 24 carat gold is at Rs13,908 per gram, up by Rs38. The 18 carat variant is priced at Rs10,435 per gram, up by Rs29.

    Kanpur reports 22 carat gold at Rs12,750 per gram, a rise of Rs35, while 24 carat gold is at Rs13,908 per gram, up by Rs38. The 18 carat gold rate stands at Rs10,435 per gram, gaining Rs29.

    In Kolkata, 22 carat gold is priced at ₹12,735 per gram, up by Rs35, while 24 carat gold stands at Rs13,893 per gram, gaining Rs38. The 18 carat gold rate is Rs10,420 per gram, higher by Rs29.

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  • In Unexpected, First-of-Its-Kind Action, FCC Adds All Foreign-Produced Uncrewed Aircraft Systems and UAS Critical Components to Covered List – Wiley Rein

    1. In Unexpected, First-of-Its-Kind Action, FCC Adds All Foreign-Produced Uncrewed Aircraft Systems and UAS Critical Components to Covered List  Wiley Rein
    2. FCC bans foreign-made drones over national security, spying concerns  Politico
    3. REEx Review: Drone Wars Heat Up, U.S. Market, Imports, and Supply‐Chain Overhaul  Rare Earth Exchanges
    4. XTI Aerospace and Drone Nerds Poised to Lead U.S. Commercial Drone Market Amid New FCC Action on Foreign-Made UAS  marketscreener.com
    5. US ban on DJI sparks Taiwan drone investment in America  digitimes

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  • Biohaven Provides Update From Phase 2 Proof-of-Concept Study with BHV-7000 in Major Depressive Disorder

    Biohaven Provides Update From Phase 2 Proof-of-Concept Study with BHV-7000 in Major Depressive Disorder

    NEW HAVEN, Conn., Dec. 24, 2025 /PRNewswire/ — Biohaven Ltd. (NYSE: BHVN) (“Biohaven”), a global clinical-stage biopharmaceutical company focused on the discovery, development, and commercialization of life-changing therapies to treat a broad range of rare and common diseases, today reported results from a Phase 2 proof-of-concept study evaluating BHV-7000 for the treatment of major depressive disorder (MDD). The study did not meet its primary endpoint, a reduction of depressive symptoms as measured by change in the Montgomery Åsberg Depression Rating Scale (MADRS) over six weeks compared with placebo. Trends favoring BHV-7000 were observed in some clinically relevant subgroups, including participants with more severe depression at screening and baseline, on primary and secondary outcome measures (see Figures 1-3). Overall, BHV-7000 was safe and well-tolerated with adverse events mostly mild and moderate in intensity and largely resolved spontaneously. The only individual adverse events occurring with an incidence above 5% were headache (10.7% and 9.9% in BHV-7000 and placebo, respectively) and nausea (4.2% and 5.6% in BHV-7000 and placebo, respectively). A low incidence of central nervous system adverse events was observed, consistent with BHV-7000’s lack of GABA activity and with safety data from previously reported studies. Additional analyses are ongoing and the company plans to present the results at an upcoming scientific meeting. The company considers the depression subgroup analyses as hypothesis generating but based upon strategic prioritization of its portfolio does not plan on additional psychiatric clinical trials to keep resources focused on key priority areas of immunology, obesity and epilepsy in 2026.

    Ahmed Tahseen, MD, Development Lead for Depression at Biohaven, commented, “There is an urgent need for novel therapies for depression that require the exploration of new mechanistic approaches to this common disorder. Although the results of this study do not support the efficacy of BHV-7000 in a broad population of depressed patients, we appreciate the commitment of the patients, investigators, and study teams who have advanced the field assessing new therapeutic approaches and made this important research possible.”

    Biohaven management will be presenting at the annual J.P. Morgan Healthcare Conference in San Francisco in January 2026 and intends to provide extensive updates across the breadth of its clinical programs, notably including:

    • clinical data for two of its extracellular degrader programs from initial patient experience in the Phase 1b expansion cohorts BHV-1400 for IgAN and BHV-1300 for Graves’ disease;
    • expectations for the company’s recently initiated Phase 2b study with taldefgrobep alfa in obesity
    • oncology clinical stage assets;
    • and emerging data from its ongoing clinical trial with BHV-7000 in adult focal epilepsy

    About Biohaven 
    Biohaven is a biopharmaceutical company focused on the discovery, development and commercialization of life-changing treatments in key therapeutic areas, including immunology, obesity, neuroscience and oncology. Biohaven is advancing its innovative portfolio of therapeutics, leveraging its proven drug development experience and multiple proprietary drug development platforms. Biohaven’s key clinical and preclinical programs include Kv7 ion channel modulation for epilepsy and mood disorders; MoDE™ and TRAP™ extracellular protein degraders for immunological diseases; and myostatin-activin pathway targeting agents for neuromuscular and metabolic diseases, including SMA and obesity. For more information, visit www.biohaven.com.

    Forward-looking Statements
    This news release includes forward-looking statements within the meaning of the Private Securities Litigation Reform Act of 1995. The use of certain words, including “continue”, “plan”, “will”, “believe”, “may”, “expect”, “potential first-in-class”, “potentially”, “groundbreaking” and similar expressions, is intended to identify forward-looking statements. Investors are cautioned that any forward-looking statements, including statements regarding the future development, timing and potential marketing approval and commercialization of development candidates, are not guarantees of future performance or results and involve substantial risks and uncertainties. Actual results, developments and events may differ materially from those in the forward-looking statements as a result of various factors including: the expected timing, commencement and outcomes of Biohaven’s planned and ongoing clinical trials, including the studies of opakalim; the timing of planned interactions and filings with the FDA; the timing and outcome of expected regulatory filings; complying with applicable US regulatory requirements; the potential commercialization of Biohaven’s product candidates; and the effectiveness and safety of Biohaven’s product candidates. Additional important factors to be considered in connection with forward-looking statements are described in Biohaven’s filings with the Securities and Exchange Commission, including within the sections titled “Risk Factors” and “Management’s Discussion and Analysis of Financial Condition and Results of Operations”. The forward-looking statements are made as of the date of this news release, and Biohaven does not undertake any obligation to update any forward-looking statements, whether as a result of new information, future events or otherwise, except as required by law.

    MoDE and TRAP are trademarks of Biohaven Therapeutics Ltd.

    Investor Contact:
    Jennifer Porcelli
    Vice President, Investor Relations
    [email protected]
    +1 (201) 248-0741

    Media Contact:
    Mike Beyer
    Sam Brown Inc.
    [email protected]
    +1 (312) 961-2502

    SOURCE Biohaven Ltd.

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  • Audit of the State Ethics Commission

    In accordance with Section 12 of Chapter 11 of the Massachusetts General Laws, the Office of the State Auditor has conducted a performance audit of the State Ethics Commission (SEC) for the period July 1, 2022 through June 30, 2024.

    The purpose of our performance audit was to determine the following:

    • to what extent SEC ensured that Statements of Financial Interests (SFIs) were filed on time and completed in accordance with Sections 3(f), 5(a)–(c), and 5(g)(10) of Chapter 268B of the General Laws;
    • whether SEC conducted initial staff reviews of violations involving conflicts of interest and the filing of SFIs in a timely manner in accordance with its internal practices; and
    • whether SEC issued advisory opinions in a timely manner in accordance with its internal practices.

    Below is a summary of our finding, the effect of that finding, and our recommendation, with hyperlinks to each page listed.

       
    Finding 1
     
    SEC should update its internal control plan (ICP) annually, as required by the Office of the Comptroller of the Commonwealth’s (CTR’s) Internal Control Guide.
    Effect If SEC does not annually review, and update as needed, its ICP and other policies and procedures, then SEC staff members may not have clear guidance, leading to inconsistent practices, inefficiencies, and a higher risk of noncompliance with laws and regulations. A lack of written policies and procedures can also hinder staff member training, accountability, and continuity of operations for managing SFI filings and advisory opinions.
    Recommendation
     
    SEC should establish and implement a formal process to review and update its ICP and policies and procedures. This process should include documenting the performance of an annual review, as required by CTR’s Internal Control Guide and state law.

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  • Asian Legal Business Again Recognizes Ning Zhang Among the Top Dealmakers in Asia – News

    Asian Legal Business Again Recognizes Ning Zhang Among the Top Dealmakers in Asia – News


    Press Release




    December 24, 2025

    HONG KONG, December 24, 2025: Partner Ning Zhang has been named to Asian Legal Business’s 2025 Dealmakers of Asia list. This marks the third consecutive year he has been recognized among the region’s most influential and accomplished legal professionals who have made significant contributions to the dynamic landscape of Asian business law and are shaping the future of dealmaking across the continent.

    Ning advises clients on transactions involving mergers and acquisitions, private equity, venture capital, and capital markets, including in the United States and Hong Kong. He has handled complex cross-border transactions involving both private and listed companies and represents international financial institutions, private equity funds, and multinational corporations in investments, acquisitions, and divestments throughout the Greater China region. Ning also focuses on emerging business matters, counseling Chinese companies through all stages of their lifecycle.

    See the complete Dealmakers of Asia 2025 list >>

    In Hong Kong, Morgan, Lewis & Bockius is a separate Hong Kong general partnership registered with The Law Society of Hong Kong.

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  • Journal of Medical Internet Research

    Journal of Medical Internet Research

    Many people use peer online forums to seek support for health problems. Forums allow users (people who read or post on a forum) to engage in anonymous, asynchronous, text-based communication with those who share similar experiences. Current research suggests a wide range of impacts from using forums, but little understanding of why these impacts vary across forum designs and for different people. More research is needed to understand how forums work to inform decisions around whether they should be funded, promoted, and used by individuals. However, such studies require developing a detailed ethical framework and navigating many practical challenges in applying this. How data are collected and used impacts not only the validity of the research but also directly on how safe forum users feel. If users feel their data are being used for purposes that they do not agree with, fully understand, or have consented to, then this could leave them feeling unsafe and ultimately lead them to leave the forum. Conversely, if users feel their data are being used for purposes they agree with, fully understand, and have consented to, they will feel safe to use the forum. Most previous research in this area has used either online surveys (eg, []), user interviews (eg, []), or analysis of forum posts (eg, []), often in one specific forum. Each method raises ethical and practical challenges, but published discussion of these is limited, often to a brief statement to confirm ethical approval or, that in the case of forum post analysis, the data are already in the public domain with no expectation of privacy, and therefore no ethical review is needed. Both positions are problematic. Ethics committees and institutional governance bodies can ensure that research is conducted in accordance with overarching ethical principles (eg, the Declaration of Helsinki 1964 []), and relevant national and international laws (eg, General Data Protection Regulation [GDPR] []; and the Online Safety Act in the United Kingdom []; California Consumer Privacy Act [CCPA] []), but rarely do they include experts in online technological advances, or societal concerns. For example, while open online forum posts may be publicly available, they are generally assumed by users to be nonidentifiable and offered in a specific context, for a particular purpose. When posts are taken out of this context and used for research, their meaning changes, and users no longer have the option to edit or remove their own data. If posts are quoted in research outputs, they may then be used for purposes with which the user disagrees. The user, who thought they were anonymous, may also be identifiable through reverse internet searching [].

    Drawing on the Improving Peer Online Forums (iPOF) study [] as a case study, we share learning on key issues relevant to developing an ethical framework for studies evaluating online forums or collecting and analyzing online personal data more broadly. We hope this will help guide future researchers, ethical committees, and funding bodies. We refrain from proffering definitive guidelines because we agree with Gliniecka [] who argues for a “situated ethics approach” to researching online spaces, that is flexible, relational, contextual, responsive to change, and informed by the forum users. As such, each study needs to refine its own ethical framework.

    See iPOF case study details in .

    Textbox 1. iPOF case study.

    The iPOF study is a realist-informed mixed methods evaluation of multiple UK mental health forums, provided by health care services, charities, or commercial organizations. The aim was to develop a program theory to explain how online mental health forums impact users’ mental health and well-being and to use this theory to develop best practice tools to improve uptake, safety, and usefulness of online forums [].

    In developing an ethical framework, we worked closely across our multidisciplinary research team and our forum partners. We drew on existing guidelines and frameworks including The UK Government Data Ethics framework [], the British Psychological Society Ethical Guidelines for Internet-Mediated Research [], and the Ethical Guidelines for the Association of Internet Research []. We worked closely with our NHS host Trust Information Governance Lead to gain Trust Research and Development (R&D) approval and Lancaster University Information Officer (MA) to write a Data Protection Impact Assessment (DPIA) [] for sponsorship approval.

    We designed the study to be as transparent as possible. At the outset, we published an open-access detailed protocol paper [], our realist synthesis [], our ethical framework including how data will be managed [], and our statistical analysis protocol []. We promoted the study in open online forums and invited people to ask questions and comment. This ensured that participants consenting to the study were making informed decisions, and that other forum users who chose not to take part could access this information.

    The iPOF study was funded by the National Institute for Health and Care Research (NIHR), hosted by Berkshire NHS Foundation Trust in the United Kingdom and conducted in collaboration with researchers at Lancaster University and the University of Manchester.

    Randomized controlled trials are often cited as the gold standard of health technology assessment [], but are not well-suited to evaluating existing peer online health forums. Access to existing forums cannot be controlled without severely disrupting the ecological validity of the forum, and identifying a valid control group is problematic. Further, given the range of forum types and diversity of possible intended and unintended impacts already reported in the literature [], it is unlikely that forums either “work” or do not “work,” so identifying a single primary outcome is often a challenge. Attempts have been made to conduct randomized controlled trials in which online forums have been set up primarily for the study (eg, []), but establishing a functioning forum community takes a long time and is challenging and expensive [].

    Realist evaluations offer an alternative and potentially more suitable approach to evaluating forums already flourishing []. Realist evaluation is grounded in realist philosophy and starts by eliciting a program theory about how an intervention works. This theory is then tested and refined iteratively, drawing on observational data methods, to develop a deep understanding of what works for whom, why, and in what context. However, these observational studies have their own ethical and practical challenges.

    See iPOF study design details in .

    Textbox 2. iPOF study design.

    We wanted to study how forums work in the real world, while minimizing any impact of the research on the functioning of the forum community. We chose a realist-informed multiple case series design in which we recruited 7 forums, purposively sampled for diversity across forum hosts (organization responsible for the platform), target population, forum design (including level and nature of moderation, whether they require registered login, and notification systems), and size and engagement level of population. Forums were identified using snowballing techniques and online searching.

    We developed a program theory about how forums work based on previous literature and interviews with key stakeholders, exploring intended and unintended positive and negative impacts, and understanding how different forum designs might work differently for different users. We then tested these theories using a combination of surveys, interviews, and qualitative analysis of forum posts.

    Each participating forum signed a collaboration agreement outlining how they would work as equal partners in the research to ensure forum users’ views were prioritized throughout. This required: (1) forum hosts to be actively involved in the research process and design decisions, including engaging in host collaboration meetings, and promoting data collection and involvement in a Patient Public Involvement (PPI) and co-design group to forum users; and (2) to only share forum data that were either openly available to the public with no expectation of privacy, or consent had been freely given to share data for research purposes by users at sign-up. Freely given consent was defined as users having the option to share data but this not being a requirement for forum use.

    Forums were paid by the research funder for time spent in research activity in accordance with NIHR guidance [] but no money was paid to generate a profit from the sharing of data. Forums were deidentified using bird names and described in relation to contextual factors identified in the realist synthesis. The study was overseen by an independent Study Steering Group, including methodological and lived experience experts.

    The main methods used to understand user experiences in online forums include online surveys, interviews, and computational, linguistic, or qualitative analysis of forum posts. Each of these methods has limitations and ethical and practical challenges. Triangulating data or findings from across these methods can address some of the limitations but can also raise additional challenges.

    Online surveys offer an inexpensive, relatively quick way to invite large numbers of forum users to contribute data on a broad range of questions, which allow statistical analysis of quantifiable outcomes in a way that is convenient for participants and maintains their anonymity. They are less susceptible to social desirability bias and can include data from users who read forums but never post, which is crucial as this subgroup makes up the vast majority of forum users []. Surveys can be repeated to investigate change over time. However, surveys need to be designed to accurately assess the concepts being investigated, sensitively worded, and not too arduous to complete. Responders need to be sufficient in number, broadly representative, attentive, anonymous, and consenting. Extensive guidance on survey design already exists (eg, [,]), so here we focus only on ethical and practical challenges specific to online surveys evaluating peer online health forums.

    Assessing Important Outcomes

    Where possible, health interventions should be evaluated using well-validated health outcome measures. However, such measures are hard to find for the kinds of outcomes that peer support interventions are thought to impact. Rather than reducing physical or mental health symptoms per se, peer support approaches are valued for their positive impacts on acceptance, hope, and normalization []. A lack of well-validated measures to use for these concepts, or long burdensome measures, may require evaluators to generate bespoke items for their study, focusing specifically on what they hypothesize will change with forum use.

    Where validated measures are used, it is important to screen them for risk-related items and consider how responses on these items will be managed. Online health forums are populated by users who, given their health status, may be at increased risk of harm to self and are also anonymous. If survey respondents complete a survey entirely anonymously, then sharing generic information about how to access support may be sufficient to manage risk. However, for surveys collecting personal details such as email address to send payment or links to follow-up surveys, it may be better to remove specific risk items. Asking users to share limited personal information (an email address) that identifies the individual but does not provide sufficient personal information that would be needed to manage any risk issues (eg, general practitioner details) could be considered unethical.

    Surveys are often used longitudinally pre- and postintervention to assess health care impacts. However, forum use often does not have a clear start and end point, as users dip in and out as required. Consequently, analysis of change between “preintervention” and “postintervention” is generally not suitable. If surveys are administered only to new users joining the forum, these will fail to capture the experiences of long-term users, who are often crucial to the functioning of the forum community, unless there is a very long follow-up period. Therefore, surveys often capture a snapshot of activity within the forum. To address this in any analysis, it is important to include items to assess individual forum use patterns, including time since they started to use the forum.

    Facilitating Participation

    Surveys in online forums generally rely on convenience sampling. Links to survey items are circulated and promoted among the users, with the aim of recruiting a sufficient and broadly representative sample of users to power statistical analysis to test the study-specific hypotheses. Recruiting and retaining sufficient and representative samples is a big challenge. Studies to date have generally reported low completion rates and lower retention rates for longitudinal surveys, even when financial incentives are used []. Methods for promoting the survey can vary between posting adverts in the forum, scrolling advertising banners, and directly emailing or messaging a database of users, all of which will attract the attention of different kinds of users.

    Considering careful sampling criteria, providing valued incentives that are not deemed coercive, and standardizing advertising strategies across forums can all help generate adequate samples, the representativeness of which can sometimes be tested, using the demographics collected at forum registration. However, providing incentives can cause problems as they attract the attention of “bad actors” (users who try and take part more than once, people outside of the forum who pretend to be forum users, and bots [autonomous programs on the internet]). More personalized telephone or even face-to-face contact may enhance participation but at the cost of significant resources.

    Validating Participants

    Bad actors can be managed by limiting participation to preregistered participants (where these exist), one attempt per email address, and monitoring for suspicious email addresses, such as containing random letters [] and unlikely patterns of activity (eg, several similar email addresses arriving at the same time []). Bots are a particular concern in open forums that can be accessed without first setting up individual accounts. Some survey providers have CAPTCHA (Completely Automated Public Turing test to tell Computers and Humans Apart) built into the software, for example, Qualtrics. However, it should be noted that more recent versions (eg, reCAPTCHA v3) collect personal data without informing the user, which is shared with Google [], which can be noncompliant with GDPR; and artificial intelligence systems are increasingly able to solve CAPTCHA problems [].

    Even if responders are real people who do meet inclusion criteria, the offer of an incentive may motivate them to take part, but not to attend to the items, resulting in meaningless data. They may also be incentivized to complete the survey multiple times to receive multiple payments. Several strategies exist to screen for this, including looking for unlikely patterns in responding (all items rated at one extreme end), completion times that are impossibly quick, and attention items that are objectively easy and should generate predictable responses if the responder is concentrating. All of these are useful strategies that can be used to “clean” the dataset. However, ethically, incentives still need to be paid to bad actors and suspected bots as it is very difficult to know for sure that this is what they are. Penalizing people who could possibly be genuine responders with attentional problems, which are inherent in many health problems, is unethical. This can result in an expensive dataset and waste of public money.

    See iPOF survey details in .

    Textbox 3. iPOF survey.

    Assessing Important Outcomes

    All forum users aged 16+ were invited to take part in a survey, built in REDCap (Vanderbilt University) []. Separate surveys were created, with different links to share in different forums, so it was possible to monitor which forums participants had found the survey from. Survey data were collected between June 2023 and June 2024.

    The survey was designed in line with principles proposed by Westthorp et al [] to directly test our program theories and to sample participants for interview. The survey consisted of 2 well-validated mental health outcomes: Generalized Anxiety Disorder – 7 (GAD-7) [] and Patient Health Questionnaire – 8 (PHQ-8) [] plus bespoke items designed to assess specific contextual and mechanistic concepts within the iPOF initial program theories.

    The GAD-7 and PHQ-8 assess anxiety and depression and allow comparison with people using the national “NHS Talking Therapies” services program which uses the same measures. The PHQ-8 was used rather than the PHQ-9 because we removed the risk item that assesses suicidal ideation. The survey was used to capture a snapshot of activity and was delivered at 0, 6, and 12 weeks to allow analysis to explore changes over time. The statistical analysis plan was published prior to completing data collection [].

    Facilitating Participation

    A Participant Information Sheet was designed with extensive host and PPI involvement, to be brief and informative, including signposting participants to additional support resources to manage risk. Inclusion criteria and consent were taken using online check boxes, with the final decision to consent to submit data made at the end, once all items had been completed. An attempt was made to standardize how participants were recruited in each forum, by sharing the same advert wording in each forum. However, some forums also shared the survey by email with registered users to help increase recruitment. Recruitment and retention were incentivized by offering £10 digital shopping vouchers at each time point. Automated emails were used for follow-ups, with up to 2 reminders sent per follow-up.

    Validating Participants

    First, participants gave informed consent to participate in the study. To complete the online consent form, they needed to complete ReCAPTCHA v2 (Google Inc), confirm that they met all inclusion criteria, and enter a valid email address that had not been previously entered. The Participant Information Sheet was available to view here. A total of 2901 consents were received. After consenting, a unique link to the survey was automatically emailed to the participant. A total of 1554 complete surveys were received.

    Piloting indicated that attentively completing the survey in less than 5 minutes would be impossible, so all participants who completed the survey in less than 5 minutes were excluded from the data analysis and were not invited to the follow-up surveys. A total of 440 respondents were excluded due to this, leaving a total of 1114.

    This group was invited to the follow-up surveys; 576 completed the 6-week follow-up and 532 completed the 12-week follow-up.

    After survey data collection was complete, the following variables based on the email addresses of respondents were used to clean the dataset of responses suspected to be from bots or bad actors. Responses were excluded if:

    1. the email address domain name was 1 of 8 flagged as being a temporary email address, often used for abuse, by online cybersecurity firms (eg, IPQuality Score []) including; Tupanda, Seosnaps, Tospage, Rohoza, Fkcod, Fahih, Laymro, and Oprevolt
    2. the email address was very similar (5 or fewer characters difference) to another respondent’s email address submitted to the same forum);
    3. the first part of their email address (before the “@”) conformed to a regular pattern of characters that was so common (>250 respondents) we considered it to represent a fraudulent actor making multiple, possibly automated, survey completions. The pattern was: 1 uppercase letter, 3‐12 lowercase letters, 1 uppercase letter, and 3‐12 lowercase letters.

    This resulted in a final, cleaned, dataset of 791 participants at baseline, 368 participants at the 6-week follow-up, and 342 at the 12-week follow-up. This compares favorably with previous survey evaluations of online mental health forums that have reported follow-up rates of only 16.6% at 6-week follow-up on similar measures [].

    Interviews offer a way to develop an in-depth understanding of how online forums work through detailed questioning of individuals purposively sampled to address the key questions being asked, and as such are used extensively to evaluate health interventions. As with surveys, people who use forums but never post can also be part of this dataset. However, specific ethical and practical issues arise in interviewing forum users that are concerned with inclusion and anonymity.

    Facilitating Participation

    Interviews are generally conducted one-to-one and in-person either face-to-face or via video conferencing. This facilitates rapport and a flexible dynamic approach that can lead to deeper insights into a participant’s experiences and, as such, is very personal. This approach may be particularly unappealing for people who are drawn to forums because of the anonymity and remote asynchronous communication, such as people on the autistic spectrum [] or who may feel stigmatized by their health condition.

    Alternative interviewing styles should be considered that may be more inclusive, including online text-based chat style conversations, which could be done remotely and over longer periods of time. There is some evidence that this can generate high-quality data [] but can also lead to practical challenges when aiming for a purposive sample if an incentive is offered for taking part. The more remote the interviewee, the harder it is to assess whether they meet the sampling criteria. As surveys, incentives can attract “bad actors” who may pretend to be forum users when they are not.

    Language can also be a practical barrier. Even if people are using a forum in which communication is predominantly through one language, this does not mean that they feel confident to take part in an interview in this language. Having the option to involve interpreters for interviews may support people from minority ethnic groups to take part, which is crucial if we are to learn about how forums support health for underserved communities.

    Protecting Anonymity

    Care is also needed in sharing and storing data. Interviews are commonly recorded and transcribed, and this should be done using contracted transcribers with relevant confidentiality agreements as part of the research team. Transcripts should be fully deidentified, including removing references to names, places, or the specific health forum, before being stored. In studies in which only one forum is being studied, it can be difficult to hide the identity of the forum, but where multiple forums are being studied, deidentifying each forum, as well as individuals, can greatly reduce the chances of any one individual being recognizable. This should extend to any quotes from participants that are used to illustrate and validate the reporting of analytic findings. Finally, it is not possible to fully anonymize interview data and therefore, the full transcripts should be considered sensitive data and not shared openly.

    See iPOF interviews details in .

    Textbox 4. iPOF interviews.

    Facilitating Participation

    Interviewees were primarily sampled from survey respondents, using a theoretical sampling approach informed by responses on key survey items relevant to the specific program theories being tested. For example, psychological safety is a key feature of forums that determines how users engage with them. We invited users from across the range of responses to a survey item asking how safe they felt on the forum. This allowed us to explore what generated a feeling of safety and what individual and contextual factors were needed to support a sense of safety. Interviews took place between August 2023 and November 2024.

    To enhance our inclusive approach, we also purposively sampled people from the forums who had not completed the survey (by advertising directly in the forum space), and people from ethnic minority groups who used forums, or had considered using forums but chosen not to, in order to understand what factors influenced this behavior.

    We offered $39 shopping vouchers to all participants, in line with Health Research Authority (HRA) guidance []. We were contacted by people we suspected to be bad actors. Some claimed to be from particular demographic groups but this was at odds with their online profiles. Others claimed to have used forums, but then were unable to name any or describe how they worked. We introduced a short screening call using video conferencing in which the interviewer could first gauge demographic characteristics and forum use experience.

    Our interview topic guides were informed by realist interviewing methods [] initially open and inviting participants to share their views about online forums, and gradually funneling to more specific questions to test specific program theories. All topic guides were co-designed with our PPI group, who also offered us the opportunity to practice interviewing and refine the guides. The core elements of the topic guide are available in .

    Protecting Anonymity

    Anonymity of participants was ensured through the usual interview procedures of deleting audio data as soon as the file is transcribed and checked; working with a contracted transcriber; and deidentifying transcripts before storage. We took the additional step of deidentifying all forums, by allocating each forum a code name of a UK bird. These codes were used throughout the project to help us keep data linked across different parts of the project, while reducing any risks of identification. The key linking the code to the forum was stored separately from the data. Bird names will be used to refer to forums in all publications and presentations to maintain this secure code. Quotes will be attributed to deidentified individuals within a coded forum.

    Analyzing forum posts offers a way to see exactly what is happening in forums in real time and without being filtered through the reflections of the participants, or the social desirability and demand characteristics of surveys or interviews. As well as analyzing which topics are being discussed, the metadata attached to forum posts can be used to assess underlying mechanisms of how forums work that members may not be consciously aware of, including the style of language used, speed of responses to posts, etc. Forum post data can also be easy and inexpensive for researchers to collect and free of cost or effort from forum members. However, this method of data collection is ethically and practically the most problematic.

    Gaining Consent

    Some forums ask users to consent for their data to be used for research (and often other third-party uses) at registration within the terms and conditions, but use of the forum then depends on them agreeing with these terms. Consequently, this consent is not valid as it is not freely given. Notable exceptions exist in which users are able to opt out of sharing for research and still use the forum, for example, Kooth []. This raises different practical (and by implication) ethical concerns about the validity of the data. Posts in forums are generally relational and part of a larger conversation. Analyzing only a subset of these posts from those who consent allows for certain kinds of analyses, for example, topic modeling [], keyness analysis [], and sentiment analysis [] but prevents analysis of the fully contextualized interactions.

    Many researchers argue that users in forums in which posts are openly and publicly accessible have no expectation of privacy, and that therefore this can be considered public data not subject to the same GDPR requirements []. Thus, much research is done using Reddit (Reddit Inc) and X (formerly known as Twitter; X Holdings Corp). However, this argument has been challenged on the grounds that even if users do not expect privacy of their posts, this does not equate to agreeing to have their data taken out of context and used for other purposes including research []. When posts are analyzed by a researcher, they can be interpreted and used to support a viewpoint that the original author may not agree with. Unfortunately, asking for individual consent in open public online health forums is not a solution, as many of the users would never see the request, resulting in the fragmented, decontextualized dataset mentioned above.

    A better understanding of public opinion about the use of online health forums for research, and of existing consenting processes in forums, is needed. Some users are likely to want their data to be used for research, or at least some research. A similar public debate about wider sharing of health data without consent suggests that public willingness to share data varies widely depending on the demographics and clinical characteristics of the individual data providers; who the data are being shared with; how well users feel they understand what is being shared and why; the type of data; perceived motivation of the data users; the possible impact of the data user on individual care; how much control individuals feel they have, how much choice, and whether there is a feedback loop so they can see the impacts of data sharing; and financial incentives, especially when data were shared with people making profit from it [].

    Collecting data for research always requires weighing up costs to the individual and society versus the potential benefits to the individual and society. If forums are to play a role in offering support for people with health conditions, then we need to better understand what their impacts are, how they work, and for whom. Forum posts offer a unique way to do this. However, it cannot be at the cost of users feeling unsafe to post in the forums, as psychological safety is fundamental to the continued use and sustainability of forums []. This dilemma has led some researchers to focus their analyses on forums that are already closed, for example, Reddit subreddits (eg, []), and therefore no risk of disrupting the community. But as Adams et al [] have argued, inactive forums remove completely the option of users to remove or edit their data. In line with GDPR, we all have the right to be forgotten online []. Posts in live forums can generally be edited and deleted by the user, but once a forum is archived or scraped from a website and saved in a database for research, this right is lost. Further, there are no active moderators (forum staff who oversee online conversations) to support collaborative working, and this research could still cause distress to ex-users and impact the use of other online health forums if general trust in forums is eroded.

    Protecting Anonymity

    Although often deidentified through use of individually chosen usernames, forum posts are rarely completely anonymous: usernames are often linked to personal details recorded at signup or sometimes reflect the names or identifiable characteristics of an individual; content of posts often refers to people or places that can identify individuals. Users with rare conditions, unusual characteristics, or who hold specific roles, for example, forum moderators, are also at increased risk of being identified. Therefore, forum posts need to be treated as personal sensitive data, with consent needed to share these data for research.

    Further important decisions are needed around storage, use, and sharing of forum posts. Storage needs to be done in accordance with the national law, which in the United Kingdom is clearly set out in the GDPR and the Data Protection Act 2018. Forum posts should be deidentified prior to being shared by replacing usernames with a PIN and names of people or places. Deidentified data should be stored in a Secure Research Environment with restricted access and a named researcher who has the responsibility to delete the data after a specified number of years. Forum posts should not be shared as part of the Open Science Framework (OSF []). Even when extensive work has gone into deidentifying the dataset, the amount of qualitative data from any one individual increases the risk of users being identified. Sharing the data also removes the right for the person to remove or edit their data (the right to be forgotten), unless the dataset can be accessed and edited by individual users, which would be very difficult but not impossible to implement. Smaller segments of data could be used as quotes in publications to support any forum analysis, but careful paraphrasing needs to be done to ensure these cannot identify individuals by searching for the quote online. For some kinds of qualitative analysis, for example, thematic analysis, this may not be too problematic, but for linguistic analysis, this can alter the characteristics of the data in ways that potentially undermine the analysis itself.

    Collaborative Working

    All health research should be a collaborative endeavor with service providers and users. This is particularly crucial for studies using online health forum data where individual consent is not always possible. Decision-making relies on a comprehensive and transparent ethical framework. Close collaboration with forum users, and with hosts and moderators who understand the users of each particular forum is essential to ensure that ethical frameworks are comprehensive and comprehensible [,]. Consent given without choice or to very long and incomprehensible terms and conditions documents is not valid. In some instances, this collaborative working may help forums to improve the way in which consent for research is offered.

    Avoiding Function Creep

    Analysis of forum data should be limited to the aims of the research for which consent was given by individual users or collaboratively agreed with forum hosts and moderators. PPI at all levels of decision-making, including within the research team and ethics committees, is essential to ensure users are driving what data are used for and to prevent “function creep.” This occurs when researchers use data for purposes beyond the purpose originally approved []. Forum posts can create very large datasets, which could be used for a wide range of analyses, and while there are ethical issues in not making the most effective use of data, careful monitoring is needed to ensure researchers are not tempted to use the data for functions beyond their approved use. For example, while consent may have been given for forum posts to be used for some aims, for example, to improve the design of forums for user accessibility, it cannot be assumed that the same consent would have been given for more contentious aims such as to diagnose, predict behaviors, and identify risks, based on algorithms [].

    Managing Risk

    Finally, a challenge in analyzing forum data that is easily overlooked is the risk of exposure to distressing material for the analyst. Some forums contain highly distressing material, some of which, especially in health forums, may have personal relevance for the people analyzing the data. Careful consideration is needed to design an individualized supervision and support plan for everyone in contact with the data. The necessity of this may be obvious to health researchers, especially those with a clinical background, but less familiar to researchers embedded in computational or linguistic disciplines.

    See iPOF forum posts details in .

    Textbox 5. iPOF forum posts.

    Forum posts were collected for the period between March 2016 and March 2024.

    Gaining Consent

    During the setup of iPOF, we discussed the study design with the national Confidential Advisory Group (CAG) [] which provides expert advice on the use of confidential patient information. We were advised that the iPOF study did not require a CAG review as none of the data are considered personally identifiable health data, including forum posts in an NHS-hosted forum in which usernames are linked to patient records. This advice is at odds with the Information Commissioner’s Office which suggests that usernames count as “online identifiers” and should be considered personally identifiable information []. This highlights the lack of a clear consensus on what defines identifiable data. We took the more conservative approach and chose to treat all forum posts as potentially identifiable, sensitive data.

    For forums in which users can freely give consent at sign-up (ie, they can still use the forum without consenting to this), we used only posts made by consenting users. This resulted in access to 53% of data from one forum. For publicly open forums, we posted about the study onto the forum, with a designated email inviting questions and debate, and we developed in close collaboration with the forum moderators. We gave users the option to email if they wanted their posts removed from the dataset. This led to one user posting that they had checked out our website and found the very detailed outline very reassuring, and there were no further comments or requests for data to be removed. For forums in which consent was not requested at sign-up, or was not freely given, we asked the forum hosts to invite all users to take part by email that included a link to a participant information sheet and an informed consent form. Only data from users who completed this were shared with the research team. In smaller communities, this was easier to do as a greater proportion of the users were still active users and contactable, but this still only led to approximately 4.8% consent. In large forums, this method was not possible due to the higher turnover of users. With one forum, we discussed whether their forum sign-up process could be changed to include consenting for research as an option, rather than a requirement. This did not happen, as the hosts were concerned that this change would reduce the number of people joining the forum, so we could not use any of these forum posts as data. However, the hosts’ decision was at odds with feedback from our PPI group, who felt revising the consent process in this way would enhance trust and increase sign-ups. This is an interesting hypothesis that needs testing. Finally, we considered analyzing posts from forums that have already closed but decided against this as the ethics of this needs further exploration with forum users, which was beyond the scope of iPOF.

    Protecting Anonymity

    All forum datasets were deidentified at the forum and individual levels. Each forum was allocated a UK bird name, and participants were given a PIN to replace their usernames. All names and places were redacted using a combination of manual editing and automatic named entity detection methods. Data were transferred using secure data transfer protocols and stored on secure servers controlled by Lancaster University. The databases will not be openly shared at the end of the study, and all quotes will be paraphrased to reduce the risk of identification of individuals.

    Collaborative Working

    Forum hosts, moderators, and users were embedded throughout the project. Our coapplicant research team included 2 lived experience experts (CL and KM), and a forum moderator (SW). We used a PPI lead (NC) and established a PPI and co-design group. Altogether, 22 PPI participants were recruited, with 13 online forum moderators, 4 forum users, and 5 public advisors. The group met monthly by Zoom for 22 sessions, which were hosted by 2 independent facilitators. Approximately 9 participants and 6 members of the research team attended each session. During the study setup, the group provided feedback on the survey design and interview topic guide, but over time, most sessions were focused on co-designing an animation and a training resource for moderators.

    We established a Host group including senior staff involved in forum design and delivery at host organizations. Between 4 and 10 representatives from forum partners attended 5 group meetings, facilitated by PM and FL. Their main role was to advise on the development of forum design guidelines, a key output of the iPOF project. Finally, our Study Steering Group included 2 people with lived experience of using mental health forums, as well as methodologists familiar with the ethical and practical challenges outlined. They met 6-monthly to support the study, including discussion of how to manage the ethical and practical challenges that arose.

    Avoiding Function Creep

    To avoid function creep, the Chief Investigator (CI) was designated as the person responsible for future access to the data, and with responsibility for checking the function of any future use meets current ethical approval, or that further approvals are sought.

    Managing Risk

    Given the potentially distressing and triggering focus of the study, all members of the research team, including those employed for their lived expertise and those employed for their methodological or clinical expertise, were offered a well-being plan. This involved meeting with the PPI lead (CL) to identify possible stressors, likely indicators of stress, and how the individual would like the team to respond to these. Regular supervision with a clinical psychologist (FL) was also offered to staff directly analyzing forum posts and interviewing data.

    All methods outlined above for studying health forums are based on different philosophical assumptions and have inherent strengths and weaknesses that limit the conclusions that can be drawn. Where multiple methods are used, triangulation offers valuable opportunities to integrate the learning from across these methods. Drawing on Denzin [] and [], triangulation in the evaluation of health forums can occur at each of 3 levels.

    Triangulating Methods

    The first is the methodological level, that is, addressing the same research question by looking at different findings from a range of different methods, for example, Jamison et al [] analyzed interview transcripts of stroke survivors visiting the general practitioner and forum posts made in an online stroke forum, showing how the 2 data sources complemented the findings from each. Similarly, Thi et al [] successfully triangulated survey data from pregnant women using a Vietnam-based health service with interview data from other stakeholders in the services to understand mental health help-seeking behaviors. However, triangulating across methods to evaluate online forums can also highlight important philosophical differences. Statisticians may value modeling of survey data collected over time, using standardized questionnaire measures, and assuming that causality can be inferred from examining how changes in one variable precede changes in another; qualitative interviewers may assume that generative causality lies at a deeper level of reality and can only be understood through in-depth interviews to explore how participants react and respond to their experiences within the forum, and corpus linguistics may assume that individuals may not even be aware of how forum use impacts them and that this can best be gleaned from studying subconscious patterns in the language they use. Understanding the value and limitations of each of these approaches is important in realizing the benefits of triangulating them.

    Triangulating Individual Data

    The second level of triangulation is the individual participant level, where we can look at data from the same individuals across different methods. This is possible when studying forums, if participants are invited to take part in surveys and interviews through the forum, and the same individuals consent for their forum posts to be analyzed. Additional ethical and practical issues emerge. Additional consent is needed to link these data sources, on top of that given to collect each of the individual sources. The more information that is linked about a person, the greater the chances they become identifiable. In essence, the study moves away from being “issue-centered” toward becoming more “actor-centered” with increased risks for individuals []. It is important that participants fully understand the implications of data linkage, and working with a PPI group to find clear ways to communicate this is essential. Triangulating at the individual levels also adds a practical challenge in ensuring that the individual identifiers across the datasets can be matched. For example, in surveys and interviews, participants are often identifiable by name or email address, but in forums, a unique username or PIN is used. Requesting both items of information at the additional consent stage is necessary to ensure the data are linkable.

    Prioritization and Interpretation

    Finally, the third level of triangulation is in prioritization and interpretation across different stakeholder groups. Understanding online health forums lends itself very well to interdisciplinary working, stakeholder collaboration, and public and patient involvement, but also highlights significant differences across these groups in what should be prioritized in the findings. This can best be navigated by recognizing these differences at the outset of the study and building in regular opportunities to review the findings and collaboratively agree on what will be taken forward. These can be done online to reduce time, resources, and environmental impact, though some face-to-face collaboration may be needed to build rapport and maintain a collaborative approach across the team. Keeping in mind the aims of the study and the priorities of the funding body can help resolve potential conflict and keep the project on track.

    These 3 levels of triangulation are not mutually exclusive, and in the iPOF study, we have attempted to work at all 3, with varying degrees of success.

    See iPOF triangulation details in .

    Textbox 6. iPOF triangulation

    Triangulating Methods

    Realist evaluations encourage the use of any methods that can test the realist theories proposed; however, to date, they have relied heavily on qualitative interview methods []. We are still working out how best to triangulate findings from the iPOF survey, interviews, and forum posts. Our experience is that descriptive statistics (context and hypothesized outcomes) from the survey, qualitative analysis of interview data, and linguistic analysis of forum data sit easily within a realist approach, at all stages of theory generation and testing. Hence, we are triangulating these to look at the impacts of forums on mental health outcomes. The practical challenge is publishing them together in an academic journal paper, simply because of the number of words needed to describe all of the methods. The use of statistical models to test realist theories is more challenging. Statistical models often assume linear relationships, are interested in average outcomes, require ever larger numbers to test more complex theories, and aim to show successionist causality. In contrast, our theories are nonlinear, often hypothesize multiple contextual factors triggering multiple mechanisms to generate any one outcome and aim to understand underlying generative causality. We are still working on this challenge.

    Triangulating Individual Data

    Individuals taking part in iPOF consented separately to take part in the survey, interview, or share their forum posts. They could also provide additional consent to have their forum post data linked to their survey data, interview data, or both by providing their username within the forum or email address. This additional consent was explained in a separate participant information sheet, which was developed with our PPI group to ensure it was clear and transparent. Of the 791 valid survey responses, only 105 consented to link these data to forum posts, compared to 478 who consented to be contacted for an interview, and only 18 consented to linking all 3 data sources. This suggests that some triangulation may be more acceptable to participants than others, and that the data are likely to be severely limited.

    Prioritization and Interpretation

    iPOF was funded by the NIHR with a clear focus on the clinical implications of evaluating online mental health forums. This focus was maintained by regular meetings of forum hosts and a PPI and co-design group to codevelop the key outputs including an animation, an e-learning toolkit for moderators, and design guidelines for forums. The theoretical papers outlining the underlying mechanisms by which forums were thought to “work” were developed primarily to inform these clinical outputs, and discipline-specific methodological developments were considered tertiary to this. An independent Study Steering group that met approximately 6-monthly was a helpful guide in steering the project toward the agreed outcomes.

    Consistent with our ethos that the perspectives of people with lived experience are essential to any discussion of the ethical and methodological challenges of online research, we first present the following commentary from a forum user and moderator.

    Lived Experience Commentary by Luciana Vega

    There are real ethical issues and difficult challenges when considering the vast amount of data in online forums, aiming for meaningful research results. It is reassuring to see here an effort directed at unwrapping different angles and placing a focus on where further consideration might be necessary. It is clear we need to better understand how and why peer support forums work, and an ethical approach is paramount.

    I believe the paper explores some challenges well, such as cleaning the dataset from nongenuine users, the difficulties of verifying legitimacy in a largely anonymous, faceless population, and the consent issues of analyzing forum posts. It considers all perspectives on these issues. It would be interesting if the paper had explored the ethical issues when using data from the moderator’s experience too. Also, it only briefly mentioned the idea of a long-term study in a forum specifically designed for data collection, and apart from the funding issue, it would be helpful to have this option further discussed and the ethical issues a “living laboratory” would bring.

    I agree with the paper’s suggestion that there is a need to further discuss the ethical costs and benefits of understanding forum designs. Basically, how to balance the ethical priorities versus the need to answer important questions. Any approach that would overcome the main ethical challenges would enable the creation of valuable guidelines for existing platforms. It is accepted that online forums are an easy to access and wide-reaching service that complements other valuable services. However, more research is needed to fully understand what works well and not so well. I believe there is still an urgent need to identify solutions to the main ethical barriers to valid and significant online forum research. This paper suggests some, but more effective solutions are still needed.

    Research Team Commentary

    Online forums offer a valuable opportunity for users to share and seek health-related support that is grounded in lived expertise and is easy to access, at a time when health services around the world are struggling to meet demand. Understanding how forums work is important but has inherent ethical and practical challenges. To have ecological validity, research needs to study active forums without disrupting the culture and without relying on highly controlled methods. Impacts for individuals vary widely, are determined by the interactive conversations and therefore are not independent and are not easily measured by standardized measures. There are no clear pre- and postintervention time points, as users dip in and out at will. Evaluation requires triangulating data across a range of qualitative and quantitative methods that are inclusive of users who post in forums as well as those who only read, all of which raise challenges in recruiting and validating participants. Drawing on learning from the iPOF study, we have explored some of the key challenges, including assessing important outcomes, facilitating participation, validating participants, protecting anonymity, gaining consent, managing risk, multistakeholder engagement, and triangulation. iPOF focuses specifically on understanding online forums to support mental health. It may be that forums supporting other health conditions, or other kinds of online spaces, for example, social media platforms, will identify further issues to consider.

    Our experiences have highlighted the importance of conducting research in this area, but without risking the trust and psychological safety needed for users to share their personal and sensitive experiences online. The ethical and practical challenges inherent in this are not easily addressed, and the context in which decisions are being made to address these is changing fast. Ethical approval at the outset of a study from a recognized ethics committee is necessary but not sufficient in this context, as many do not have the relevant expertise or connections to scrutinize the changing landscape of societal views. It can be helpful to consider research in this area as an ongoing costs and benefits analysis of the risks of doing the research versus not, but with an awareness that different disciplines and stakeholder groups will have different perspectives that all need to be considered.

    We designed iPOF with clear benefits in mind, that is, to develop clinical tools to support hosts and moderators in improving forums for users. We have shared our learning from trying to address the challenges that arose in the hope it will be of value to others designing or reviewing online forum evaluations. We anticipate further risks that we have not yet addressed. Findings may suggest some forum designs are linked to more positive outcomes than others, risking reputational damage for the latter. Concluding that forums can have positive impacts on supporting health could be used to argue for increased funding to support forum delivery, but at the expense of, rather than in addition to, support for other interventions such as talking therapies. Advances in technology and specifically the increased presence of artificial intelligence and bots will fundamentally change the face of online forums, creating new benefits and risks that we cannot yet anticipate.

    Having independent steering groups that include a diverse range of stakeholders is essential in all research, but particularly in this area, to ensure that the potential benefits and possible costs for all stakeholders are surfaced and inform decisions being made. Transparency in decision-making throughout the project, including a diverse and fully engaged PPI group, publicly sharing an ethical framework, inviting debate, and learning from previous research, can all help to ensure decisions are accommodating changes in societal context. Structured frameworks such as DECIDE [] have recently been published to help guide researchers through the key issues to consider in using online data and address many of the issues discussed in this paper. However, further work is needed to maintain safe spaces in which users can openly explore and debate the ethical and practical challenges in evaluating peer online health forums as they evolve technologically and socially to ensure research benefits and avoid harming online health communities that so many users value for the support they offer.

    We would like to acknowledge the invaluable support from the participating forums and all the participants who have taken part in the iPOF study, to protect anonymity, the forums are not individually named. We also thank Chris Lodge, Service User Researcher, in advising on the overall design and delivery of the project.

    This study is funded by the NIHR Health and Social Care Delivery Research (HS&DR) (NIHR134035). The views expressed are those of the author(s) and not necessarily those of the NIHR or the Department of Health and Social Care. The study is hosted by Berkshire Healthcare NHS Foundation Trust. The Sponsor is Lancaster University. Additional support comes from the NIHR Clinical Research Network, NIHR North-West Coast Applied Research Collaboration (ARC), and Oxford Allied Health Sciences Network (AHSN).

    FL, SJ, KM, PR, and ES all contributed to the overall study design, securing of funding, data collection, and analysis. ZG, JH, CH, PM, TR, HR, NC, JV, and RJ were all involved in data collection and analysis. GH gave consultative advice on ethical and governance issues. All authors approved the final draft of the paper.

    None declared.

    Edited by Amaryllis Mavragani; submitted 05.Mar.2025; peer-reviewed by Colleen Young, Sue Kilpatrick; final revised version received 13.Oct.2025; accepted 15.Oct.2025; published 24.Dec.2025.

    © Fiona Lobban, Neil Caton, Zoe Glossop, Jade Haines, Gemma Hayward, Connor Heapy, Rose Johnston, Steve Jones, Chris Lodge, Karen Machin, Paul Marshall, Tamara Rakic, Paul Rayson, Heather Robinson, Elena Semino, John Vidler. Originally published in the Journal of Medical Internet Research (https://www.jmir.org), 24.Dec.2025.

    This is an open-access article distributed under the terms of the Creative Commons Attribution License (https://creativecommons.org/licenses/by/4.0/), which permits unrestricted use, distribution, and reproduction in any medium, provided the original work, first published in the Journal of Medical Internet Research (ISSN 1438-8871), is properly cited. The complete bibliographic information, a link to the original publication on https://www.jmir.org/, as well as this copyright and license information must be included.

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