Dear all, 

Recently, it's been 14 days since our last Pre-Action to HSA. A few days ago, HSA sent a reply to our letter. 

This coming Sunday 2 June from 2-5p.m, I'm calling for those who care about what is happening to join us in a closed door meeting. This will also be in preparation for our Hong Lim Park Event. 

To Register: 
https://bit.ly/htd2june

We have lots to update and lots to prepare in the days ahead as we will be submitting to file in court formally. 

To Support: 
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PAYNOW: 98291678 (JR Software) We are building an AI that can file Judicial Review whenever the government is Out of Line. This is how we intend to keep the government in check. 

Watch my reply: Is HSA a Secret Society? 
https://vt.tiktok.com/ZSY63cCCq/

Read Raymond Ng's Administrative Reply: 

To: Mr Yang Director,

Legal, Health Sciences Authority (HSA)

Cc Dr. Choong May Ling Mimi Chief Executive Officer Health Sciences Authority (HSA) 11 Biopolis Way, #11-01 Helios Singapore 138667

Email: CHOONG_May_Ling@hsa.gov.sg, HSA_Reply@hsa.gov.sg Mr Yang, 
Cc Dr Choong

Subject: Immediate Judicial Review of HSA's Failure to Act on Pfizer's Celebrity Vaccine Promotion 

1. We refer to your response dated 29 May 2024 regarding our pre-action letter dated 17 May 2024 and our subsequent communications. 

2. We would proceed with filing for locus standi application before the formal judicial review processes. You may still contact us via email if you so wish, as we move on to the other processes of this process. 

3. So in this letter, | shall summarise our points to prove that our demands are not vexatious and we consider all these point before we submit; Procedural Impropriety 

Procedural Impropriety

4. We wish to emphasize that the core thrust of our judicial review is the HSA’s omission to act against Pfizer for their use of celebrity endorsements in the "Project Vax" event. This omission, in our sincerest beliefs, constitutes a procedural impropriety. The regulations clearly prohibit such endorsements, and failing to enforce these rules undermines the integrity of the regulatory framework established to protect public health.

5. The essence of our legal argument is that the HSA’s inaction in this matter represents a failure to uphold the Health Products (Advertisement of Specified Health Products) Regulations 2016. By not taking appropriate enforcement action, the HSA is allowing a significant breach of these regulations to go unaddressed, which may set a concerning precedent for future advertising practices. It is our firm belief that this inaction is not only legally questionable but also detrimental to public trust in the regulatory processes designed to safeguard health and safety.

6. We are committed to pursuing this judicial review to ensure that the principles of procedural fairness and regulatory compliance are upheld, thereby protecting the public from potential undue influence and ensuring that health product promotions adhere strictly to established legal standards.

Claims of Confidentiality

7. Additionally, while we acknowledge that the details of HSA’s review of Pfizer’s "Project Vax" event are currently confidential, this confidentiality does not preclude the necessity of transparency when mandated by a Court of Law. If the Court compels you to reveal the details of your investigation, it will provide the needed clarity on whether the omission to act was justified. Therefore, it is all the more important for us to proceed with this judicial review and address these concerns through the legal system.

8. The Court may compel you to reveal the criteria and steps of investigation without mentioning Pfizer’s content too. 

9. Should you choose to apply for a gag order to prevent us from disclosing details of your investigation into Pfizer, we wish to make it clear that we reserve the right to contest such an application. Additionally, if the Court issues a gag order without any application, we reserve the right to appeal against such an order. The public interest in this matter is significant, and maintaining transparency is crucial to upholding public trust in the regulatory process. 

10. Given the potential impact on public health and the importance of regulatory compliance, we believe it is vital for the details of Pfizer’s promotional activities and the HSA’s corresponding actions or inactions to be disclosed. As such, we reserve the right to appeal to the Court to lift any gag order that may be issued or to prevent it from being issued in the first place. Ensuring that this information is accessible to the public is essential for maintaining accountability and confidence in the regulatory framework.

11. By pursuing this judicial review, we aim to ensure that the enforcement of health product advertising regulations is carried out with transparency and integrity. The public has a right to understand the basis of regulatory decisions, especially when they pertain to significant matters of public health and safety. Therefore, we are prepared to take all necessary legal steps to ensure that the judicial review process is conducted openly and fairly. 

Interpretation Act (Singularity & Plurality of Noun Used in the Law) 

12. Moreover, we contend that an event designed to promote vaccination inevitably promotes a plural number of therapeutic products. The "Project Vax" event, while ostensibly focused on the general concept of vaccination, inherently endorses multiple vaccines. Each vaccine constitutes a therapeutic product, and the collective promotion of these vaccines falls within the purview of the Health Products (Advertisement of Specified Health Products) Regulations 2016. 

13. Under the Interpretation Act, words in the singular include the plural, and vice versa. Therefore, the legal framework governing advertisements of health products must be interpreted to include the promotion of multiple products when discussing a category such as vaccination. This means that promoting vaccination as a general concept is tantamount to promoting all vaccines within that category. Such promotion, if endorsed by celebrities, directly contravenes the prohibition outlined in Section 2.4.9 of the regulations. 

14. The law's phrasing in singular nouns does not exclude the plural forms; rather, it encompasses them. By interpreting the regulations in this manner, it is clear that any advertisement—whether it promotes a single product or a category of products—must adhere to the same stringent guidelines. Consequently, Pfizer's use of celebrities to endorse vaccination in general is, by extension, an endorsement of multiple therapeutic products, thus falling squarely under the legal prohibition against celebrity endorsements. 

15. Itis essential to consider the legislative intent behind the Health Products (Advertisement of Specified Health Products) Regulations 2016. The purpose of these regulations is to prevent undue influence in the promotion of therapeutic products by prohibiting celebrity endorsements. It is inconceivable that the legislative intent was to prosecute only those who advertise a singular product using celebrities, while allowing those who promote multiple products in the same manner to escape scrutiny. 

16. The spirit of the law is to ensure that all forms of endorsement by celebrities, whether for a single product or a category of products, are prohibited to protect public health and prevent misleading promotions. This interpretation aligns with the broader objective of the regulations: to safeguard consumers from being swayed by the influence of celebrities, whose endorsements could overshadow medical facts and evidence. Allowing promotional activities that endorse a category of products using celebrities would undermine the very purpose of the regulations and create a loophole that could be exploited to the detriment of public health. 

17. In light of this, the omission to act on Pfizer's use of celebrities to promote vaccination not only contradicts the letter of the law but also its intended purpose. By not addressing this violation, the HSA risks setting a precedent that could weaken the enforcement of health product advertising regulations, ultimately compromising the regulatory framework designed to protect consumers. 

18. We firmly believe that the HSA's failure to act on this matter not only overlooks a significant regulatory breach but also undermines the intent of the law designed to prevent undue influence in the promotion of therapeutic products. It is imperative that the regulations are enforced consistently to maintain public trust and ensure that health communications remain free from improper endorsements. 

Not About Prosecutorial Discretion 

19. I understand that this judicial review is not intended to challenge the HSA's prosecutorial discretion. Instead, the focus is squarely on the omission to act against Pfizer for their use of celebrity endorsements in the promotion of vaccination. Given the lack of disclosed information, it is impossible for us to determine whether any investigation has been conducted regarding Pfizer's actions. As a concerned citizen, | am not obliged to assume that an investigation was conducted and subsequently decided not to prosecute. 

20. Without transparency on this matter, we must consider the possibility that no investigation was undertaken or that any investigation did not adequately address the core issue: the use of celebrity endorsements to promote vaccination in general. Such endorsements advertise a plural number of therapeutic products, despite not explicitly naming specific brands or products. Additionally, Pfizer's promotion of vaccination as a category can be perceived as indirectly marketing its own therapeutic products, thus contravening the regulations. 

21. It is essential to clarify that the endorsement of vaccination by celebrities, regardless of whether specific brands are mentioned, still constitutes a violation of the Health Products (Advertisement of Specified Health Products) Regulations 2016. The regulations explicitly prohibit any form of endorsement by celebrities due to the undue influence such endorsements can have on public perception and decision-making. Promoting a category of products effectively masks the advertising of multiple products, and this indirect promotion should be scrutinized under the same regulations that govern direct endorsements. 

22. For the avoidance of doubt, your colleague Ms. Jalene clearly stated that advertising a category of products does not contravene the law. This reply is further confirmed by Mr Yang, Director of Legal, HSA, and | have found out that you were working in AGC, so your answer is definitive of HSA's stand. This answer would mean that all investigative effort on Pfizer would not consider the Interpretation Act (regarding interchangeability of singular and plural nouns) mandating of considering that advertising “vaccination” via celebrity endorsement in effect advertises plural number of therapeutic products. HSA's omission to consider this is squarely at the central issue of our pending Judicial Review - procedural impropriety. 

23. Furthermore, it is crucial to understand that prosecutorial discretion cannot be exercised in a vacuum, especially when the initial investigation may have already filtered out what should be considered for prosecution. If an investigation does not fully address the issue at hand, such as the celebrity endorsement of vaccination in general, then the decision not to prosecute cannot be considered a valid exercise of prosecutorial discretion. 

24. Prosecutorial discretion presupposes that a thorough and impartial investigation has taken place, one that considers all relevant aspects of the alleged violation. In this case, if the investigation did not encompass the full scope of Pfizer's promotional activities—specifically the use of celebrities to endorse vaccination as a category —then the subsequent decision not to take enforcement action is fundamentally flawed. This filtering process, whether intentional or due to oversight, undermines the integrity of the regulatory enforcement mechanism. 

25. Without transparent data revealing the extent and findings of any investigation into Pfizer's actions, we are left with significant uncertainties. As citizens, we are not obligated to assume that the HSA conducted a comprehensive investigation and then exercised prosecutorial discretion appropriately. Instead, we must infer that either no investigation was conducted, or if there was one, it did not sufficiently address the core issue of celebrity endorsements promoting multiple therapeutic products via promoting “vaccination”. 

26. This situation creates a problematic scenario where the regulatory body might prematurely dismiss potential violations from consideration for prosecution. Such an outcome not only weakens the enforcement of health product advertising regulations but also erodes public confidence in the regulatory framework designed to protect consumer interests. 

27. It is imperative that the judicial review examines whether the HSA's omission to act was a result of a deficient investigation process. Prosecutorial discretion cannot be validly exercised if the investigation itself was inadequate or improperly scoped. Ensuring that all relevant factors are thoroughly investigated and considered is fundamental to upholding the principles of fairness and accountability within the regulatory system. 

28. By initiating this judicial review, we seek to bring clarity and accountability to the enforcement of health product advertising regulations. It is essential that the regulatory body adheres to its mandate without prematurely dismissing potential violations through an incomplete investigative process. This review aims to restore public trust and ensure that all promotional activities are held to the highest standards of compliance with established legal guidelines. 

Conclusion 

29. In conclusion, we wish to emphasize that our actions are motivated by a profound sense of duty to the Republic of Singapore. As concerned citizens, we cannot, and are not obliged to, turn a blind eye when we witness a government agency omitting to act in the face of what we believe to be a clear regulatory violation. Our pursuit of a judicial review is driven by the lack of information available to us, which has left us with no other recourse but to seek judicial intervention. 

30. We are undertaking this action for the sake of our country, to ensure that the regulations designed to protect public health are upheld and enforced consistently. Transparency and accountability in regulatory actions are vital to maintaining public trust and safeguarding the well-being of our citizens. 

31. This letter serves as a formal record of our concerns and our commitment to seeking justice through the legal system. Should the issue of legal costs arise at any stage of the proceedings, we will present this letter as evidence of our genuine and well-founded attempts to address the matter through appropriate channels before resorting to judicial intervention. 

32. We hope that through this judicial review, we can achieve clarity and ensure that all promotional activities for therapeutic products adhere to the highest standards of compliance with the law. We remain open to communication proceed with the court filings immediately. 

Yours faithfully, 

Ng Kai Hoe Raymond & Iris Koh Hsiao Pei representing other potential litigants to
be revealed at a more suitable time & forum. 

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PAYNOW: 98291678 (JR Software) 
We are building an AI that can file Judicial Review whenever the government is Out of Line. This is how we intend to keep the government in check.