“…The essential procedures of the study never changed substantially, despite exchanges of over 15,000 pages of material among the nine sites.'' Review processes and content varied widely across multiple IRBs [2,[6][7][8]10,[13][14][15][16][17][18][19][20][21][22][23][24][25]. This includes variation in the type of review, as well as variable reactions to the study protocol and materials.…”