The 1905 Supreme Court case, Jacobson v Massachusetts, defines a vaccine as a substance that prevents infection by a pathogen and also prevents spreading it to others. Martin says Moderna, the manufacturer of a new Covid-RNA injection, describes its product not as a vaccine, but as "gene-therapy technology" in SEC filings. This is because neither Moderna or Pfizer (the other manufacturer of the injections) makes any claims about their products creating immunity or preventing transmission. The best they can offer is that it is expected to lessen symptoms. Moderna's own clinical study says it is "impractical to measure infection." The New England Journal of Medicine and Lancet reported that "no correlate of protection from SARS-CoV-2 has been established," which means that there is no evidence that the injections protect against anything. Martin concludes that Moderna and Pfizer are in violation of the Federal Trade Commission's Act, which prohibits deceptive practices.