First, the Pharmaceutical Research and Manufacturers of America (PhRMA), of which respondent is a member, publishes a ???Code on Interactions with Healthcare Pro-fessionals.??? See PhRMA, Code on Interactions with Healthcare Professionals (PhRMA Code) (rev. July 2008), available at <a href="http://www.phrma.org/sites/default/files/108/">http://www.phrma.org/sites/default/files/108/</a> phrma_marketing_code_2008.pdf.