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This declaration was filed by Peter W. Pappas, Ph.D, in F.T.C. v. Western Dietary Products Co (Skookum) et al. (C01-818R, W.D., Washington), a case in which the Federal Trade Commission sued a company that was marketing devices and herbal products based on recommendations by Hulda Clark.

Declaration of Peter W. Pappas, Ph.D.

May 9, 2001

Peter W. Pappas, Ph.D, pursuant to 28 U.S.C. § 1746, hereby states as follows:

1. My name is Peter W. Pappas. I am a United States citizen over the age of 18. I currently reside in Columbus, Ohio.

2. 1 have a B.A.degree in biology from Humboldt State University in Arcata, California, awarded in 1966. In 1968 1 received an M.A. in Biology from Humboldt State University. I received a Ph.D. in 1971 from the University of Oklahoma, Norman, Oklahoma, in zoology, parasitology, and biochemistry. I served a post-doctoral fellowship through the National Institutes of Health fi-om 1971-1973 at Rice University in Houston, Texas in parasitology, and served as research associate at Rice in parasitology in 1973.

3. From 1973 until 2000 1 was a faculty member at The Ohio State University in Columbus, Ohio. I served as an Assistant Professor from 1973 through 1977, as an Associate Professor from 1978 through 1982 and as Professor of Zoology from 1983 through 2000. From 1989 through 1998 1 was chairman of the Department of Zoology at Ohio State. (The Departments' name was changed to "Evolution, Ecology, and Organismal Biology" in 2000.) In 1998 and 1999 1 was the Director of the Introductory Biology Program at Ohio State. I am now retired from Ohio State, having been awarded the title of Professor Emeritus, and I am a technical consultant for LabBook-com in Columbus, Ohio. LabBook.com develops and markets commercial software for managing laboratory information and mining genomic databases.

4. My specialized academic training is in the area of parasitology -- the study of parasites. In general terms, "parasitologists" study all aspects of the "biology of parasites," including, but not limited to, (1) taxonomy and systematics, (2) life cycles, (3) pathology, (4) epidemiology (including the distribution, control, and eradication of parasitic infections), (5) and treatment of parasites and parasitic infections. Parasitologists might specialize in one or more of the above areas, they might specialize in the study of parasites infecting a specific host (e.g., "human parasitology"), or they might specialize in other biological disciplines related directly to one of the above areas (e.g., biochemistry of parasites in relation to chemotherapy). Many biologists with specialized training in other biological disciplines study parasites as "'model systems," including evolutionary biologists, molecular biologists, taxonomists and systematists, and ecologists. Parasitic organisms are extremely diverse -- virtually every major group of animals has at least one member that is a "parasite," and in some groups of animals all members are parasites. Just like parasites, parasitologists are also extremely diverse in terms of "what" they study and "why" they study it.

5. While a faculty member at Ohio State University, I maintained an active research program in parasitology, primarily biochemistry, physiology, and cell biology of parasites. I have published approximately 90 articles in refereed scientific journals and edited three reference books. I have also served on the editorial boards of five national/international parasitological journals, and I currently serve as co-moderator of the primary parasitology news group on the web (bionet.parasitology). My CV is attached.

6. At Ohio State University, my primary teaching responsibility for 27 years was an advanced undergraduate/graduate-level course, Introductory Parasitology. As part of maintaining the course's content with contemporary parasitological concepts and principles, I have read extensively in many areas of parasitology and "human parasitology." This includes reading and studying many general, human, and veterinary parasitology textbooks written in the U.S. or U.K., and extensive readings in the original literature (refereed scientific journals). For the past five years I have maintained a large web site (Parasites and Parasitological Resources) designed as (1) a teaching aid for college-level students and (2) a source of information for the lay person. The web site contains information on over 200 species of parasites and over 500 photographic images of parasites, and most of the important parasites of humans are included. During a typical month, the web site's home page receives more than 10,000 hits, and the entire web site receives >150,000 hits. Through an e-mail link in this web site, I receive and answer many questions from all over the world regarding many aspects of parasitology. The web site's URL is www.biosci.ohio-state.edu/~parasite/home.html.

7. I became aware of Hulda Clark's claims regarding parasites and disease in 1996 when I developed my web site. As part of developing this web site, I conducted extensive searches of the web for other parasitology sites. In addition to sites that were clearly academic and instructional in content, I came across many sites that espoused the belief of Hulda Clark that parasites cause many diseases including cancer, AIDS, Alzheimer's disease, diabetes, etc. Throughout my 33 years in academia, I had never heard of nor read about such a theory. Initially, I simply ignored Hulda Clark and her theory, as I was simply too busy. However, as my web site developed, I began to get e-mails asking for my "opinion" about Clark and her theories. I also discovered that many of the "proClark" web sites had copied copyrighted images from my web site and were using them without my permission. Thus, I not only purchased Clark's books, The Cure for All Cancers (1993), The Cure for HIV and AIDS (1993), and The Cure for.All Diseases (1995), but I also began an extensive search for and investigation of "pro-Clark" web sites. Over the past few years, I have become familiar with Hulda Clark's theories and many of the web sites that support her theories and sell various cures for parasites.

8. In her writings, Clark makes a number of claims about parasites and disease. In The Cure for All Cancers, Clark states:

In this book you will see that all cancers are alike, They are all caused by a parasite A single parasite! It is the human intestinal fluke. [Clark is referring to Fasciolopsis buski, a parasitic flatworm.] And if you kill this parasite, the cancer stops immediately. The tissue becomes normal again. In order to get cancer, you must have this parasite.

9. In The Cure for HIV and AIDS, Clark states: "This [parasite] is the source of the HIV virus (sic)" and a photograph of Fasciolopsis buski follows. She goes on to say, "The HIV virus (sic) belongs to this fluke," and "[I]f it establishes itself in the thymus, it causes HIV/AIDS." Furthermore, in both of these books, Clark emphasizes that effective treatment for this parasite (and, therefore, a cure for cancer, AIDS, and may other diseases purportedly caused by this parasite) requires the use of both herbal remedies and electrical devices "Zappers").

10. The claims of Hulda Clark (and many of the web sites that sell herbal remedies and "Zapper") that (1) a single parasite causes cancer, AIDS, and many other diseases, and that this parasite can be killed with electrical devices ("Zappers") are not supported by competent and reliable scientific evidence. This statement is based on the observations and correspondence summarized below.

11. Cancer, AIDS, and many of the diseases that Clark claims are caused by Fasciolopsis buski, are distributed world-wide, yet the distribution of this parasite is limited to S.E. Asia.

12. Clark claims that she has diagnosed this parasite in everyone with cancer, AIDS, and other diseases, and that she diagnoses these infections using a "Syncrometer" (an electrical device that somehow indicates the presence of parasites and/or toxins in the body.) However, the only reliable and acceptable method for the diagnosis of Fasciolopsis buski infections in humans is demonstrating the presence of the parasite's eggs in human feces. Thus, her statement that "everyone" is infected with this parasite is based on inaccurate diagnostic methodology. Moreover, if this parasite caused all of these diseases, the parasite would be found during routine pathology procedures. I have been unable to find any evidence that this parasite is found during such routine procedures.

13. Clark's books contain a number of inaccurate statements about the biology of Fasciolopsis buski and other parasites, so one must question her as an authority on parasites or parasitic diseases. She misspells the scientific name of the parasite; she spells the specific buskii, when the correct spelling is buski. When discussing any species of living organism, the correct spelling of the scientific name is essential. In The Cure for All Cancers, the title for Figure 2 (which is not a photomicrograph) refers to "strings of eggs from the parasite -- the parasite does not produce "strings of eggs," and the eggs are microscopic (cannot be seen without a microscope). Clark states tliat "[T]he adult [parasite], though, stays tightly stuck to our intestine (or liver, causing cancer, or uterus, causing endometriosis, or thymus, causing AIDS, or kidney, causing Hodgkin's disease.)" The adult parasite does live in the small intestine, as stated by Clark, but I have been unable to find any reports (other than Clark's) of this parasite being found in the human uterus, thymus, or kidney. Clark states: "Some of these eggs [produced by the adult parasites] batch in the intestine or the blood." There is no credible evidence that the eggs of any species of fluke will batch in the human intestine, or in the blood or time. There are a few species of flukes in which the eggs normally enter the blood or tissues (e.g., the schistosomes which cause schistosomiasis), but, even with these species of parasites, the eggs do not hatch in the blood or tissue. Clark states that "[w]e all have tapeworm stages in our bodies...." and "[e]very tumor, benign or malignant, has a tapeworm stage in the middle of it, even including warts." I have been unable to substantiate either of these statements in the medical literature. Although Clark has an advanced academic degree (a Ph.D. in physiology) and an N.D., she has no academic training as a parasitologist and she clearly does not have a basic understanding of the most fundamental parasitological principles.

14. There is overwhelming evidence in the form of peer-reviewed articles appearing in scientific journals that virtually all types of cancer result from the uncontrolled division of cells, and that the uncontrolled division of cells has a genetic basis. That is, cancer is caused by the activation or inactivation of specific genes that control the division of cells; it is not caused by a parasite. If this parasite truly causes cancer and, therefore, kills thousands of people each year, how could this parasite go unnoticed? Even in areas of the world where Fasciolopsis buski is endemic, there are no published studies that demonstrate (1) a relationship between this parasite and cancer and (2) that curing this parasite cures cancer. The only studies that support these theories are those mentioned in Clark's books, and her studies lack scientific integrity. Similarly, there is overwhelming evidence that AIDS is caused by HIV (human immunodeficiency virus), not a parasite.

Although there's some disagreement as to when and where HIV was introduced first into the human population, it is clear that it was not a prevalent disease until the early 1980s. However, Fasciolopsis buski has been recognized as a human parasite for hundreds of years, a fact recognized by Clark in her books.

15. Hulda Clark believes that parasites cause many common diseases. In the terminology of the scientific method, Clark is stating a hypothesis or statement of belief. However, the scientific method requires that, for a hypothesis to be accepted as a theory, the hypothesis must be tested. That is, controlled, empirical, unbiased experiments must be done. Moreover, the experiments and their results must be reviewed by other scientists to insure that the experiments were conducted properly and that.the data are unbiased. This is what differentiates good science from bad science. Herein lies a major flaw with Clark's theories. Her hypotheses have not been tested using controlled experiments, and her methods of collecting data are biased. Rather, most of the diseases were diagnosed and treated by Clark, and Clark also claimed the diseases were cured. Thus, Clark's "case histories" represent an egregious example of a highly biased experimental protocol, and her theories are based on bad science.

16. After reading Clark's books and receiving many e-mails asking questions about Clark's theories, I tried to find information in the original literature. (The articles in refereed scientific journals or reputable reference books) that would support Clark's beliefs. Despite extensive searches of numerous major academic and medical libraries and extensive scientific and medical databases, I could not find a single article that supported Clark's theories about Fasciolopsis buski and diseases.

17. In early 1999, I posted the following statement on my web site: Hulda Regehr Clark claims that this parasite causes "all diseases, " cancer, and HIV and AIDS, and several web sites use these claims in their advertisements to sell various "cures "for these diseases. There are no peer-reviewed, published, scientific studies demonstrating that Fasciolopsis buski causes any of these diseases in humans. Furthermore, there are no peer-reviewed, published, scientific studies demonstrating that the various treatments, tinctures, cleanses, electrical devices (e.g., the "Zapper"), etc., sold through these web pages have any therapeutic value.

18. In response to the appearance of this statement, I received several e-mail messages from David Amrein, the President of the "Dr. Clark Research Association." Mr. Amrein asked that I remove this statement from my web site, and, in hopes of finding supporting information, I responded with the following: "Tell me where I can find information that supports the theories of Hulda Clark, information that has been published in peer-reviewed journals, and I will remove the comments from my web page. In fact, if you tell me where I can find this information, I will be more than happy to (1) include the information in my web page and (2) add an apology to my web page. I await anxiously your response." Despite my very clear request for information, Mr. Amrein did not provide any information that would support Clark's theories.

19. Later in 1999, Mr. Tim Bolen (who is referred to as "a media consultant" on the "Dr. Clark Research Association web site) and Mr. Leo Regehr [Hulda Clark's brother] sent a number of e-mail messages to me and various administrators at Ohio State University complaining about the statements on the website. I made them the same offer that I made to Mr. Amrein. I received no information that refutes the comments that are included in my web site. I must assume that no such information exists.

I declare under penalty of perjury, that the foregoing statement is true and correct.
Executed, this 9th day of May, 2001 at Columbus, Ohio.

Peter W. Pappas, Ph.D.

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This page was posted on June 30, 2001.