The state of the art defence : defining the Australian experience in the context of pharmaceuticals

One of the defences within Part 3-5 of the Australian Consumer Law is the state of the art, or development risk defence. This defence, although significant, has often been neglected in Australian jurisprudential analysis and has triggered at most generic academic analysis. However, with the rise of pharmaceutical and medical device litigation in Australia, it could become a vital weapon for Australian manufacturers against product liability claims. This paper will firstly review the two ways this defence could operate. It will also discuss the three types of defects which the defence could apply to. This paper aims to determine exactly when and how this defence should apply in Australia, in the context of pharmaceutical product liability claims.

The empire of cancer: Gene patents and cancer voices

In his book, The Emperor of All Maladies, Siddhartha Mukherjee writes a history of cancer — "It is a chronicle of an ancient disease — once a clandestine, 'whispered-about' illness — that has metamorphosed into a lethal shape-shifting entity imbued with such penetrating metaphorical, medical, scientific, and political potency that cancer is often described as the defining plague of our generation." Increasingly, an important theme in the history of cancer is the role of law, particularly in the field of intellectual property law. It is striking that a number of contemporary policy debates over intellectual property and public health have concerned cancer research, diagnosis, and treatment. In the area of access to essential medicines, there has been much debate over Novartis’ patent application in respect of Glivec, a treatment for leukaemia. India’s Supreme Court held that the Swiss company’s patent application violated a safeguard provision in India’s patent law designed to stop evergreening. In the field of tobacco control, the Australian Government introduced plain packaging for tobacco products in order to address the health burdens associated with the tobacco epidemic. This regime was successfully defended in the High Court of Australia. In the area of intellectual property and biotechnology, there have been significant disputes over the Utah biotechnology company Myriad Genetics and its patents in respect of genetic testing for BRCA1 and BRCA2, which are related to breast cancer and ovarian cancer. The Federal Court of Australia handed down a decision on the validity of Myriad Genetics’ patent in respect of genetic testing for BRCA1 in February 2013. The Supreme Court of the United States heard a challenge to the validity of Myriad Genetics’ patents in this area in April 2013, and handed down a judgment in July 2013. Such disputes have involved tensions between intellectual property rights, and public health. This article focuses upon one of these important test cases involving intellectual property, public health, and cancer research. In June 2010, Cancer Voices Australia and Yvonne D’Arcy brought an action in the Federal Court of Australia against the validity of a BRCA1 patent — held by Myriad Genetics Inc, the Centre de Recherche du Chul, the Cancer Institute of Japan and Genetic Technologies Limited. Yvonne D’Arcy — a Brisbane woman who has had treatment for breast cancer — maintained: "I believe that what they are doing is morally and ethically corrupt and that big companies should not control any parts of the human body." She observed: "For my daughter, I've had her have [sic] mammograms, etc, because of me but I would still like her to be able to have the test to see if the mutation gene is in there from me." The applicants made the following arguments: "Genes and the information represented by human gene sequences are products of nature universally present in each individual, and the information content of a human gene sequence is fixed. Genetic variations or mutations are products of nature. The isolation of the BRCA1 gene mutation from the human body constitutes no more than a medical or scientific discovery of a naturally occurring phenomenon and does not give rise to a patentable invention." The applicants also argued that "the alleged invention is not a patentable invention in that, so far as claimed in claims 1–3, it is not a manner of manufacture within the meaning of s 6 of the Statute of Monopolies". The applicants suggested that "the alleged invention is a mere discovery". Moreover, the applicants contended that "the alleged invention of each of claims 1-3 is not a patentable invention because they are claims for biological processes for the generation of human beings". The applicants, though, later dropped the argument that the patent claims related to biological processes for the generation of human beings. In February 2013, Nicholas J of the Federal Court of Australia considered the case brought by Cancer Voices Australia and Yvonne D’Arcy against Myriad Genetics. The judge presented the issues in the case, as follows: "The issue that arises in this case is of considerable importance. It relates to the patentability of genes, or gene sequences, and the practice of 'gene patenting'. Briefly stated, the issue to be decided is whether under the Patents Act 1990 (Cth) a valid patent may be granted for a claim that covers naturally occurring nucleic acid — either deoxyribonucleic acid (DNA) or ribonucleic acid (RNA) — that has been 'isolated'". In this context, the word "isolated" implies that naturally occurring nucleic acid found in the cells of the human body, whether it be DNA or RNA, has been removed from the cellular environment in which it naturally exists and separated from other cellular components also found there. The genes found in the human body are made of nucleic acid. The particular gene with which the patent in suit is concerned (BRCA1) is a human breast and ovarian cancer disposing gene. Various mutations that may be present in this gene have been linked to various forms of cancer including breast cancer and ovarian cancer.' The judge held in this particular case that Myriad Genetics’ patent claims were a "manner of manufacture" under s 6 of the Statute of Monopolies and s 18(1)(a) of the Patents Act 1990 (Cth). The matter is currently under appeal in the Full Court of the Federal Court of Australia. This article interprets the dispute over Myriad Genetics in light of the scholarly work of Nobel Laureate Professor Joseph Stiglitz on inequality. Such work has significant explanatory power in the context of intellectual property and biotechnology. First, Stiglitz has contended that "societal inequality was a result not just of the laws of economics, but also of how we shape the economy — through politics, including through almost every aspect of our legal system". Stiglitz is concerned that "our intellectual property regime … contributes needlessly to the gravest form of inequality." He maintains: "The right to life should not be contingent on the ability to pay." Second, Stiglitz worries that "some of the most iniquitous aspects of inequality creation within our economic system are a result of 'rent-seeking': profits, and inequality, generated by manipulating social or political conditions to get a larger share of the economic pie, rather than increasing the size of that pie". He observes that "the most iniquitous aspect of this wealth appropriation arises when the wealth that goes to the top comes at the expense of the bottom." Third, Stiglitz comments: "When the legal regime governing intellectual property rights is designed poorly, it facilitates rent-seeking" and "the result is that there is actually less innovation and more inequality." He is concerned that intellectual property regimes "create monopoly rents that impede access to health both create inequality and hamper growth more generally." Finally, Stiglitz has recommended: "Government-financed research, foundations, and the prize system … are alternatives, with major advantages, and without the inequality-increasing disadvantages of the current intellectual property rights system.’" This article provides a critical analysis of the Australian litigation and debate surrounding Myriad Genetics’ patents in respect of genetic testing for BRCA1. First, it considers the ruling of Nicholas J in the Federal Court of Australia that Myriad Genetics’ patent was a manner of manufacture as it related to an artificially created state of affairs, and not mere products of nature. Second, it examines the policy debate over gene patents in Australia, and its relevance to the litigation involving Myriad Genetics. Third, it examines comparative law, and contrasts the ruling by Nicholas J in the Federal Court of Australia with developments in the United States, Canada, and the European Union. Fourth, this piece considers the reaction to the decision of Nicholas at first instance in Australia. Fifth, the article assesses the prospects of an appeal to the Full Federal Court of Australia over the Myriad Genetics’ patents. Finally, this article observes that, whatever happens in respect of litigation against Myriad Genetics, there remains controversy over Genetic Technologies Limited. The Melbourne firm has been aggressively licensing and enforcing its related patents on non-coding DNA and genomic mapping.

Residential Differentiation, Housing Policy and Urban Planning in the Transformation from State Socialism to a Market Economy: The Case of Tallinn

The thesis examines urban issues arising from the transformation from state socialism to a market economy. The main topics are residential differentiation, i.e., uneven spatial distribution of social groups across urban residential areas, and the effects of housing policy and town planning on urban development. The case study is development in Tallinn, the capital city of Estonia, in the context of development of Central and Eastern European cities under and after socialism. The main body of the thesis consists of four separately published refereed articles. The research question that brings the articles together is how the residential (socio-spatial) pattern of cities developed during the state socialist period and how and why that pattern has changed since the transformation to a market economy began. The first article reviews the literature on residential differentiation in Budapest, Prague, Tallinn and Warsaw under state socialism from the viewpoint of the role of housing policy in the processes of residential differentiation at various stages of the socialist era. The paper shows how the socialist housing provision system produced socio-occupational residential differentiation directly and indirectly and it describes how the residential patterns of these cities developed. The second article is critical of oversimplified accounts of rapid reorganisation of the overall socio-spatial pattern of post-socialist cities and of claims that residential mobility has had a straightforward role in it. The Tallinn case study, consisting of an analysis of the distribution of socio-economic groups across eight city districts and over four housing types in 1999 as well as examining the role of residential mobility in differentiation during the 1990s, provides contrasting evidence. The third article analyses the role and effects of housing policies in Tallinn s residential differentiation. The focus is on contemporary post-privatisation housing-policy measures and their effects. The article shows that the Estonian housing policies do not even aim to reduce, prevent or slow down the harmful effects of the considerable income disparities that are manifest in housing inequality and residential differentiation. The fourth article examines the development of Tallinn s urban planning system 1991-2004 from the viewpoint of what means it has provided the city with to intervene in urban development and how the city has used these tools. The paper finds that despite some recent progress in planning, its role in guiding where and how the city actually developed has so far been limited. Tallinn s urban development is rather initiated and driven by private agents seeking profit from their investment in land. The thesis includes original empirical research in the three articles that analyse development since socialism. The second article employs quantitative data and methods, primarily index calculation, whereas the third and the fourth ones draw from a survey of policy documents combined with interviews with key informants. Keywords: residential differentiation, housing policy, urban planning, post-socialist transformation, Estonia, Tallinn

“Empire is a state of mind” – Imagining Eurasia in Russia –

Työssäni tarkastelen venäläistä neo-euraasianistista liikettä ja tapoja joilla liikkeen aktivistit rakentavat Euraasiasta yhtenäistä kokonaisuutta ja imperiumia. Keskeisiä tutkimuskysymyksiäni ovat: Mikä imperiumi on ja mitkä ovat sen keskeisiä motivaatioita ja teemoja? Kuinka imperiumin idea rakentuu tai käsitetään ja tämän voi tulkita? Minkälaisia seurauksia voi tulkita heidän tavallaan Euraasia nähdä olevan? Materiaalina käytän haastatteluja, jotka on kerätty Moskovassa keväällä 2008, ja liikkeen kirjallisia tuotoksia (lehdet ja Internet -sivut). Neo-euraasianistisella liikkeellä tarkoitan tässä työssä Kansainvälistä Euraasianistista liikettä (Meždunarodnoe Evrazijskoe Dviženie) ja sen alahaaraa Euraasianistista Nuorisoliittoa (Evrazijskij Sojuz Molodëži). Liike perustettiin virallisesti 2003, mutta rakentaa vahvasti historiallista yhteyttä 1930 -luvun klassiseen eurasianismiin. Tämän lisäksi sen diskurssissa on paljon neuvostoliittolaisia, fasistisia, uuskonservatiivisia ja nationalistisia piirteitä. Liikkeen johtohahmo on filosofi-geopoliitikko Alexandr Dugin. Työn tausta-ajatuksena minua kiinnostaa etenkin nk. älymystön tai intelligenttien vaikutus nationalismiin tai sosiaalisia ryhmiä määrittelevien diskurssien kehitykseen ja muutokseen.Tarkastelen materiaalia diskurssianalyyttisesta näkökulmasta. Näen diskurssianalyysin sen tutkimisena, miten sosiaalista todellisuutta tuotetaan erilaisissa sosiaalisissa käytännöissä. Samalla näiden diskurssien tutkiminen, foucautlaisen perinteen myötä, tarkastelee kriittisesti niiden tuottamia (aktualisoituneita sekä potentiaalisia) valtasuhteita. Käytän työssäni myös Benedict Andersonin kuvitellun yhteisön (imagined communities) käsitettä, joka auttaa hahmottamaan tapaa, jolla tutkimuskohteeni rakentavat imperiumia yhteisönä. Aktivistien puheessa imperiumi (imperiâ) tulee esiin pääasiallisesti positiivisesti ja ”heidän omanaan,” kun taas termi imperialismi (imperializm) pääosin negatiivisena, liittyen etenkin keskeisenä vihollisena pidettyihin Yhdysvaltoihin. Esiin nousee monta toisiinsa liittyvää teemaa, jotka jaottelen viideksi pääteemaksi. Näistä tarkastelen lähemmin imperiumia ”kaikkien kansojen hyväntekijänä (poliittinen puoli)”, ulkoisen voiman lähteenä (historiallis-geopoliittinen puoli) sekä kollektiivisen subjektin luojana (imperialistis-nationalistinen puoli). Pyrin kontekstualisoimaan diskurssin ja tarkastelemaan tapoja, joilla se ammentaa motiiveja myös historiallis-kulttuurisista tavoista hahmottaa aluetta ja sen asukkaita. Käsittelen myös kansan, kansakunnan, etnoksen ja nationalismin käsitteitä ja sitä, miten ne nousevat neo-eurasianistisessa diskursissa esiin. Imperiaalisen nationalismin (imperskij nacionalizm) käsite auttaa ymmärtämään niitä tapoja, jolla liike tekee sekä pesäeroa nationalismiin että samalla hyödyntää monia nationalistisen diskurssin perusteemoja. Eräs liikkeen diskurssin keskeisistä eroista niin sanottuun nationalismin valtavirtaan on ”kansakunnan (naciâ)” käsitteen vahva negatiivinen konnotaatio. Sen vastakohtana esiin nostetaan vahvasti kansan (narod) käsite. Samalla kuitenkin etnisen venäläisen (russkij) käsitettä käytetään tavallista laajemmin ja kattavammin kuin tavallisesti, ja ennen kaikkea Venäjä nousee imperiumin keskeisimmäksi tekijäksi. Euraasialaiseen imperiumiin liitetyistä positiivistista mielikuvista käsittelen tarkemmin monikansallisuuden ja kansojen kodin ideaa, joka nousee mielestäni huomattavaksi retoriseksi taustaksi kaikessa materiaalissa. Tähän liittyy vahvasti myös saman teeman sivujuonne, eli imperiumin ”vapauttava” rooli. Tulkitsen, että liikkeen imperiumi -diskurssilla on instrumentaalinen luonne: se legitimoi aktivistien vaatimuksia varsinkin entisen Neuvostoliiton alueen suhteen. ”Euraasialaisen kansan” ajatus toimii mahdollisena Euraasiaa yhteisenä tekijänä ”Neuvostokansan” tilalla. Sen taustalla materiaalistani päätellen siintävät kuitenkin enemmänkin Venäjä ja venäläis -spesifit vaateet kuin koko Euraasia. Pohdin myös kansakunnan (nation) hyljeksimisen syitä ja käsitteen sopivuutta Venäjälle, kuten myös venäläisyyden käsitteiden kerrostuneisuutta. Kokonaisuudessaan imperiumi tuli esiin abstraktina, utopistisena ja ”totaalisena” kokonaisuutena.

The State, Compartmentalization and the Turn to Local Community: A Critique of the Political Thought of Alasdair MacIntyre

Alasdair MacIntyre condemns modern politics, specifically liberalism and the institutions of the liberal state, as irredeemably fallen. His core argument is that the liberal state encourages a disempowering ‘compartmentalization’ of people’s everyday roles and activities that undermines the intersubjective conditions of human flourishing. MacIntyre’s alternative is an Aristotelian politics centred on the notion of “practice.” Defined by justice and solidarity, this politics can only be realized, he claims, within local communities which oppose and resist the dictates of the administrative state and capitalist market. Here it is argued that MacIntyre’s notion of “practice” represents a compelling ethical-political ideal. However, the belief that this ideal is best realized within local communities is rejected. In privileging local community, MacIntyre relies on a reductive view of modern states and overlooks the institutional conditions of a just polity. Against this, it is argued that a politics of human flourishing cannot succeed without an emancipatory transformation of large-scale, trans-communal institutions, in particular the state.

'Foreign' Terror? London Bombings, Resistance and the Failing State

The British government's response to the London bombings sought to make the terror of that day foreign, even though it appeared largely domestic. This helped construct it as unusual, contingent, part of the uncontrollable ‘otherness’ of the ‘foreign’. However, it also drew the response into the arena of British foreign policy, where the ‘failing state’ has been the dominant conceptualisation of insecurity and terrorism, especially since September 11th. When the bombings are examined through the ‘failing state’ disturbing and important problems are uncovered. Primarily, the ‘failing state’ discourse deconstructs under the influence of the terrorism in London, revealing that Britain itself is a ‘failing state’ by its own description and producing a generalisation of state ‘failure’. It thereby reveals several possible sites for responding to and resisting the government's representation.

Valuing the cultural monuments of Armenia: Bayesian updating of prior beliefs in contingent valuation

The most appropriate way to measure the social benefits of conserving built cultural heritage sites is to ask the beneficiaries of conservation interventions how much they would be willing to pay for them. We use contingent valuation - a survey-based approach that elicits willingness to pay (WTP) directly from individuals - to estimate the benefits of a nationwide conservation of built cultural heritage sites in Armenia. The survey was administered to Armenian nationals living in Armenia, and obtained extensive information about the respondents' perceptions of the current state of conservation of monuments in Armenia, described the current situation, presented a hypothetical conservation program, elicited WTP for it, and queried individuals about what they thought would happen to monument sites in the absence of the government conservation program. We posit that respondents combined the information about the fate of monuments provided by the questionnaire with their prior beliefs, and that WTP for the good, or program, is likely to be affected by these updated beliefs. We propose a Bayesian updating model of prior beliefs, and empirically implement it with the data from our survey. We found that uncertainty about what would happen to monuments in the absence of the program results in lower WTP amounts. © 2008 Pion Ltd and its Licensors.

Civilianizing Civil Conflict: Civilian Defense Militias and the Logic of Violence in Intra-State Conflict

This article examines how civilian defense militias shape violence during civil war. We define civilian defense forces as a sedentary and defensive form of pro-government militia that incumbents often use to harness the participation of civilians during a counterinsurgency campaign. We argue that civilian defense forces reduce the problem of insurgent identification. This leads to a reduction in state violence against civilians. However, we also claim that these actors undermine civilian support for insurgents, which leads to an increase in rebel violence against civilians and overall intensification of conflict. A statistical analysis of government and rebel violence against civilians from 1981 to 2005, and a qualitative assessment of a civilian defense force operating in Iraq from 2005 to 2009, offer strong support for our theoretical claims. These findings provide further insight into pro-government militias and their effects on violence. They also have wider ethical implications for the use of civilian collaborators during civil war.

Massachusetts Militia Claims

Full Title: Massachusetts militia claims : letter from the Secretary of War, transmitting, in pursuance of a resolution of the House of Representatives of the 15th Dec., 1826, a report upon the subject of the claims of the State of Massachusetts for certain services rendered during the late war 20th Congress, 2nd session. House Doc. no.3. Caption title. May 10, 1828 - Read, and laid upon the table. December 5, 1828- Printed by order of the House of Representatives.

Evaluating the legacies of state-building: success, failure, and the role of responsibility

What impact do international state-building missions have on the domestic politics of states they seek to build, and how can we measure this impact with confidence? This article seeks to address these questions and challenge some existing approaches that often appear to assume that state-builders leave lasting legacies rather than demonstrating such influence with the use of carefully chosen empirical evidence. Too often, domestic conditions that follow in the wake of international state-building are assumed to follow as a result of international intervention, usually due to insufficient attention to the causal processes that link international actions to domestic outcomes. The article calls for greater appreciation of the methodological challenges to establishing causal inferences regarding the legacies of state-building and identifies three qualitative methodological strategies—process tracing, counterfactual analysis, and the use of control cases—that can be used to improve confidence in causal claims about state-building legacies. The article concludes with a case study of international state-building in East Timor, highlighting several flaws of existing evaluations of the United Nations' role in East Timor and identifying the critical role that domestic actors play even in the context of authoritative international intervention

Economic valuation of an offshore wind farm in Greece: the role of individual’s base-state influences and beliefs in the value formation process

The increased concern for the impacts of climate change on the environment, along with the growing industry of renewable energy sources, and especially wind power, has made the valuation of environmental services and goods of great significance. Offshore wind energy is being exploited exponentially and its importance for renewable energy generation is increasing. We apply a double-bound dichotomous Contingent Valuation Method analysis in order to both a) estimating the Willingness to Pay (WTP) of Greek residents for green electricity produced by offshore wind farm located between the islands of Tinos and Andros and b) identifying factors behind respondents’ WTP including individual’s behaviour toward environment and individual’s views on climate change and renewable energy. A total of 141 respondents participated in the questionnaire. Results show that the respondents are willing to pay on average 20€ every two months through their electricity bill in return for carbon-free electricity and water saving from the wind farm. Respondents’ environmental consciousness and their perception towards climate change and renewable energy have a positive effect on their WTP.

The Family Novel in the Emerging Nation-State: A Comparative Study of Ba Jin’s Jia and Lev Tolstoy’s Anna Karenina

The theme of family in literature and in popular discourse occurs at times when the family as an institution is under attack. Attacks against the family coupled with defence of the family are viewed as the barometer of people’s satisfaction with the society in which they live. This outpouring of emotion, whether it is in defence of or attacking the family, is the result of the family’s position on the bridge between nature and society – a fortunate (or a detrimental) link between an individual and the units that make up a society. Across the United States and much of the western world, the battle for gay marriage and inclusive civil unions has revealed the fissures in our collective moral view of the family. The conservative concern about the absence of ‘family values’ is magnified by our situation in a world of flux. Inflation, war, terrorist threats, and the depletion of natural resources are but a few examples. When so much is unknown, how do we position ourselves? What anchors us to the past, gives us comfort in the present, and supports us in the future if not the family? Alternatively, what coddles us more in the past, shackles us more to the present, and lulls us more into a fixed conception of the future than the family? My research is not a sociological survey into the family nor does it stake any claims to understanding the present state of the family in society. The study seeks, however, to shed light on the rhetorical uses of the family by analysing two novels that are inextricably concerned with the theory of the family in times of heightened social change. In particular, my research focuses upon the social role and political meaning of the family in Anna Karenina and Jia.

Contingent Edis: a new contractual framework for minimizing the risk of incentive failures

Granting economic development incentives (or “EDIs”) has become commonplace throughout the United States, but the efficiency of these mechanisms is generally unwarranted. Both the politicians granting, and the companies seeking, EDIs have incentives to overestimate the EDIs benefits. For politicians, ribbon–cutting ceremonies can be the highly desirable opportunity to please political allies and financiers, and the same time that they demonstrate to the population that they are successful in promoting economic growth – even when the population would be better off otherwise. In turn, businesses are naturally prone to seek governmental aid. This explains in part why EDIs often “fail” (i.e. don’t pay–off). To increase transparency and mitigate the risk of EDI failure, local and state governments across the country have created a number of accountability mechanisms. The general trait of these accountability mechanisms is that they apply controls to some of the sub–risks that underlie the risk of EDI failure. These sub–risks include the companies receiving EDIs not generating the expected number of jobs, not investing enough in their local facilities, not attracting the expected additional businesses investments to the jurisdiction, etc. The problem with such schemes is that they tackle the problem of EDI failure very loosely. They are too narrow and leave multiplier effects uncontrolled. I propose novel contractual framework for implementing accountability mechanisms. My suggestion is to establish controls on the risk of EDI failure itself, leaving its underlying sub–risks uncontrolled. I call this mechanism “Contingent EDIs”, because the EDIs are made contingent on the government achieving a preset target that benchmarks the risk of EDI failure. If the target is met, the EDIs will ex post kick in; if not, then the EDIs never kick in.

Prevalence of precancerous skin lesions and non-melanoma skin cancer in Japanese-Brazilians in Bauru, São Paulo State, Brazil

Manifestações cutâneas pré-neoplásicas e neoplásicas em asiáticos são infreqüentes e pouco documentadas. O Brasil possui o maior contingente de imigrantes japoneses e 70% deles residem no Estado de São Paulo. A prevalência dessas lesões em nipo-brasileiros é desconhecida. O presente estudo tem como objetivo avaliar a prevalência de queratoses actínicas e tumores cutâneos não melanomas em nipo-brasileiros acima de trinta anos de 1ª geração ou 2ª geração, sem miscigenação, residentes na cidade de Bauru, no ano de 2006. Dos 567 nipo-brasileiros submetidos a exame dermatológico, diagnosticou-se queratose actínica em 76 pacientes, com média de idade de 68,9 anos, e único carcinoma basocelular em paciente do sexo feminino de 39 anos. No Japão, a prevalência de queratose actínica é de 0,76% a 5% e a incidência de tumores cutâneos não melanomas é de 1,2 a 5,4/100 mil. Os nipo-brasileiros de Bauru apresentaram prevalência de 13,4% de queratoses actínicas e idade mais precoce de aparecimento. Proximidade com o Equador e atividades rurais contribuem para esses achados. A presença de melanose solar demonstrou risco 1,9 vez maior de desenvolver queratose actínica.

Neuroimaging during Trance State: A Contribution to the Study of Dissociation

Despite increasing interest in pathological and non-pathological dissociation, few researchers have focused on the spiritual experiences involving dissociative states such as mediumship, in which an individual (the medium) claims to be in communication with, or under the control of, the mind of a deceased person. Our preliminary study investigated psychography - in which allegedly "the spirit writes through the medium's hand" - for potential associations with specific alterations in cerebral activity. We examined ten healthy psychographers - five less expert mediums and five with substantial experience, ranging from 15 to 47 years of automatic writing and 2 to 18 psychographies per month - using single photon emission computed tomography to scan activity as subjects were writing, in both dissociative trance and non-trance states. The complexity of the original written content they produced was analyzed for each individual and for the sample as a whole. The experienced psychographers showed lower levels of activity in the left culmen, left hippocampus, left inferior occipital gyrus, left anterior cingulate, right superior temporal gyrus and right precentral gyrus during psychography compared to their normal (non-trance) writing. The average complexity scores for psychographed content were higher than those for control writing, for both the whole sample and for experienced mediums. The fact that subjects produced complex content in a trance dissociative state suggests they were not merely relaxed, and relaxation seems an unlikely explanation for the underactivation of brain areas specifically related to the cognitive processing being carried out. This finding deserves further investigation both in terms of replication and explanatory hypotheses.