 The most influential abuses in this regard were the horrific experiments conducted by Nazi physicians during WW II (abuses perpetrated by Japanese physicians were also horrific, but have received significantly less attention). Response to these abuses led to the Nuremberg Code (Grodin &amp; Annas 1996; Shuster 1997), which is frequently regarded as the first set of formal guidelines for clinical research, an ironic claim on two counts. First, there is some debate over whether the Nuremberg Code was intended to apply generally to clinical research or whether, as a legal ruling in a specific trial, it was intended to address only the cases before the court (Katz 1996). Second, the Germans themselves had developed systematic research guidelines as early as 1931 (Vollmann &amp; Winau 1996). These guidelines were still legally in force at the time of the Nazi atrocities and clearly prohibited a great deal of what the Nazi doctors did.