In response, Drs. Leo Alexander and Andrew Conway Ivy drafted a ten-point memorandum entitled Permissible Medical Experiment that went on to be known as the Nuremberg Code.[27] The code calls for such standards as voluntary consent of patients, avoidance of unnecessary pain and suffering, and that there must be a belief that the experimentation will not end in death or disability.[28] The Code was not cited in any of the findings against the defendants and never made it into either German or American medical law.[citation needed]