On July 8, 2020 following comments were provided to the Tick-Borne Disease Working Group (TBDWG) on behalf of our organization, May12.org.

To: The Tick-Borne Disease Working Group (TBDWG), U.S. Department of Health & Human Services, and Congress

The following comments are provided on behalf of our organization, May12.org.

Members of our organization are concerned that both the Centers for Disease Control and Prevention (CDC) and International Lyme and Associated Diseases Society (ILADS) did not include the immune modulating effects of Outer Surface Proteins (Osps) in the Lyme disease case definition. Despite the available evidence, it appears the disease-causing effects of the Outer Surface Proteins shed by Borreliae are being ignored by both organizations.

Due to lipoproteins shed by Borreliae spirochetes, a large number of people who have this debilitating disease often end up with an impaired immune system that is unable to keep reactivated viruses and opportunistic infections at bay.  These facts are missing in their case definitions of Lyme disease. Victims of this outcome are frequently misdiagnosed or denied any diagnosis or proper treatment. Unfortunately, those who are not correctly diagnosed are left to suffer when it becomes chronic or late stage. Lyme disease is rarely the only infection patients have after becoming ill. People with Lyme often carry a variety of co-infections and become prone to latent viral and opportunistic infections. 

Given the known effects that lipoproteins have on the immune system, both ILADS and the CDC should be doing extensive research to fully comprehend the effects that Osps have on the immune system.

Furthermore, we have conducted a meta-analysis of the data available on Osps and found that it is imperative that Osps are  incorporated in the case definition of Lyme disease in order to accurately describe all cases of the disease. Including Osps into the Lyme disease case definition may give researchers and doctors a better understanding of why so many people relapse after treatment. It has long been documented in scientific literature that certain Osps have a direct impact on the immune system, specifically, on the Toll-Like Receptors (TLR).

There are currently two different definitions of Lyme disease. Both of these definitions, the ILADS model and the Infectious Diseases Society of America (IDSA) model, do not take into account the mechanisms of disease as demonstrated by the debacle of the LYMErix vaccine causing the same immunosuppression. Both models fail to address the key mechanisms of the disease: Immunosuppression.  Understanding how Osps affect the immune system, could also lead to better testing methods for all stages of the disease.

The only CDC-sanctioned Lyme disease testing is ANTIBODY based. People whose immune systems are damaged (immunosuppression) don’t produce the required functional antibodies to attain a positive CDC test.


The CDC’s denial of the persistence of Lyme disease is criminal, to say the least. 

230 peer-reviewed studies show evidence of persistent Lyme disease. 


This ILADS list has over 700 peer reviewed articles that support the evidence of persistence of Lyme and other tick-borne diseases. It is organized into different categories—general, psychiatric, dementia, autism and congenital transmission.
https://www.ilads.org/wp-content/uploads/2018/07/CLDList-ILADS.pdf

We at May12.org urge you to call for hearings led by the U.S. Senate Judiciary Committee, regarding the plethora of evidence revealing wrongdoing.
http://www.actionlyme.org/2017_All_9_Charge_Sheets.pdf

This evidence exposes certain officers employed by the Centers for Disease Control (CDC), Infectious Diseases Society of America (IDSA), American Lyme Disease Foundation (ALDF), and National Institute of Health (NIH), as being complicit in maintaining an ongoing harmful enterprise, which has endeavored to manipulate and capitalize on the spread of vector-borne diseases, particularly Lyme disease. This matter has been considered for prosecution in the past for scientific fraud, racketeering, slander and human rights abuses under color of law, with the following actions ensuing, to no enduring avail:

In 2006 Senator Richard Blumenthal, while Attorney General for the State of Connecticut, sued the IDSA for antitrust regarding inaccurate “Lyme” testing and diagnostics, finding significant flaws in the IDSA guidelines development process and significant conflicts of interest among the guidelines panel members.

In 2014 Senators Blumenthal, Durbin, Markey, Warren, and Brown asked the FDA to ensure scientific validity of Lyme testing, which generated correspondence from the FDA confirming the current CDC testing, diagnostic and treatment standards for Lyme disease, would be invalid.

During lobbying efforts in Washington, DC in June of 2015, advocates were advised by the legal staff of then-U.S. Senator Jeff Sessions, to pursue hearings by the Senate Judiciary Committee, for ultimate referral to the DOJ for prosecution.

Calling for a Congressional investigation of the CDC, IDSA and ALDF (over 91,749 signatures!)

https://www.change.org/p/the-us-senate-calling-for-a-congressional-investigation-of-the-cdc-idsa-and-aldf


In addition, here is evidence that CDC officer Allen Steere should be criminally charged for manipulating the current Lyme Disease definition and testing:

How did Steere leave Osp A and B out of diagnostic standard? – webpage documenting Steere leaving out Osp A and B from ActionLyme.org – The Lyme Cryme Whistleblower’s Website    . 

http://www.actionlyme.org/STEERE_IN_EUROPE.htm

First priority to open up the floodgates so all Lyme victims can receive proper recognition, proper disability evaluations, and adequate treatments:

REMOVAL of the falsified Lyme disease case definition AKA “Dearborn” -1994, which would eliminate the fraudulent two-tier Lyme testing (which misses most neurological Lyme patients).

In the end, there is plenty of research that shows certain Outer Surface Proteins can directly impact the immune system resulting in immunosuppression. Given this information, it is imperative that if the CDC/IDSA and ILADS want to develop an accurate case definition for Lyme disease, they must include the fact that the immunosuppression from OspA/Pam3Cys directly impacts the production of functional antibodies.

For more information on the science, data and sources, please see:  https://www.may12.org/lyme

Sincerely,

May12.org

Actual link to posted comment that was redacted in some spots:

https://www.hhs.gov/ash/advisory-committees/tickbornedisease/meetings/2020-7-8/written-public-comment/index.html

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