Page 30 of the pdf complaint... 154. According to CW4, the SOPs, Clinical Protocol and Case Report Forms cannot be obtained from the FDA with a Freedom of Information Act (“FOIA”) request as they are considered proprietary. 155. Plaintiff Fahey made a FOIA demand upon the FDA to obtain the SOPs, the Clinical Protocol and the Case Report Forms on the Phase II Trial, but the FDA refused to produce them. ...r