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 This DEA _issue # is easily resolved by referencing
 timolol_s PDR listed indication. If th_ DEA_s #new # theory of
 ...... utility was the accepted standard the PDR indication for timolol
 (and other glaucoma therapies) would read mretention of visual
 function, ul_q/ Significantly, no such indication is recognized
 .... in the PDR° The only _indioation m for timolol noted in the PDR
 is _reduction of intraocular pressure_ _3_/
 Nor has the Utraditional_ standard (reduction of IOP)
 been eclipseds as DEA alleges_ by the Agency's newly minted
 standard_ Xn its _Statement on Marijuana, # approved less than a
 year ago, the American Academy of Ophthalmology emphatically
 states: #To date the only clinically effective method of . o o
 [preventing damage to the optic disc_ is by lowering lOP. "!/I/
 The Alliance submits that the onlyproper indication
 for glaucoma therapy is the ntraditional,X long-accepted and
 generally recognized indication Wreduction of intraocular
 pressurep _ and that marijuana_ on the basis of all testimony_
 controlled studies and other evidence introduced in these
 proceedings, is generally accepted by the medical community as a_
 effective intraocular antihypertensive agent.
 16_/ While DEA's argument is directed at a nnew# standardt the
 Agency does not actually specify what its proposed indication
 would bee
 17q/ ACT Rebuttal Exhibit B_4. #Timoptic . _ . has been shown
 to be effective in lowering intraocular pressure .... n
 a_ ACT Brief at 176_178.
 171/ Affidavit of Dr_ Robert Hepler, Exhibit 2, nThe Use of
 Marijuana in the Treatment of Glaucomas H American Academy of
 Ophthalmology Statement as approved by the Board of Directors,
 July 21_ 1987, at Io
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