UCLA records show $765-per-specimen fetal tissue fees, raising legal questions

We must be very careful that we invoice fees for services, not sales.
Cercle's internal warning to UCLA about how to describe the $765-per-specimen charges in purchase orders.
Mark

So what exactly are we looking at here? Is UCLA buying fetal tissue illegally?

Mimi

The records show UCLA paid $765 per specimen to a tissue supplier. But the documents don't establish any violation. No charges have been filed, and the company says it was billing for procurement services, not the tissue itself.

Luke

Right, but here's what we don't know: we don't have Cercle's invoices or their cost calculations. We can't actually verify whether $765 was a reasonable fee or a price per specimen disguised as a service charge.

Mark

Why would Cercle care so much about how the billing was worded if everything was above board?

Mimi

That's the tension in the story. Cercle's own emails show they were worried that tax language could "improperly imply" they were selling tissue, which they said was illegal. So they asked UCLA to revise the purchase orders.

Luke

But that could mean two things. Either they were being cautious about language to protect a legitimate operation, or the language mattered because the substance was problematic. The documents alone don't tell us which.

Mark

What does federal law actually say?

Mimi

It prohibits fetal tissue sales for valuable consideration, but allows reasonable payments for processing, storage, transportation, and quality control. The law exists. The question is whether these fees fit within it.

Luke

And we can't answer that without the cost data. Daleiden argues the uniform $765 amount is suspicious—same price for different specimens on the same date. But that's an argument, not proof.

Mark

Did UCLA do anything wrong?

Mimi

The records don't establish that. UCLA revised its paperwork when asked. No authority has charged the university or the company.

Luke

Which is important to say clearly. But it's also worth noting that the absence of charges isn't the same as the absence of questions. The questions are real.

  • A consistent, per-specimen price of $765 attached to individual fetal liver and thymus samples raises the uncomfortable question of whether fees tracked tissue count rather than actual procurement costs.
  • Cercle's own accounts manager sounded an internal alarm in September 2023, warning that invoicing language referencing sales tax could make the company appear to be selling tissue — something federal law explicitly forbids.
  • UCLA revised its purchase orders after Cercle objected, a quiet institutional adjustment that signals both parties understood the legal stakes without resolving them.
  • The records contain no invoices or cost breakdowns, leaving the legitimacy of the $765 figure suspended between permissible reimbursement and something more troubling.
  • Neither UCLA nor Cercle has faced charges, and the documents as they stand neither establish wrongdoing nor fully exonerate either party — the truth remains locked behind redactions and missing paperwork.

In the long and contested terrain where biomedical research meets federal law, records obtained from UCLA surface a quiet but pointed question: when a university pays $765 per fetal tissue specimen to a procurement firm, does that fee reflect the permissible costs of science, or does it cross the line the law has drawn? Documents spanning 2023 to 2025 show that Cercle Allocation Services itself worried about how the charges were being described, prompting UCLA to revise its paperwork. No charges have been filed, and the underlying cost data that would answer the central question does not appear in the records.

Public records obtained through a California disclosure request show that UCLA's medical school paid tissue procurement company Cercle Allocation Services $765 for each individual fetal liver and thymus specimen across transactions spanning at least 2023 into 2025. The records include purchase orders and internal correspondence — and notably, they show that Cercle itself raised concerns about how those charges were being described on UCLA's paperwork.

Federal law prohibits acquiring or transferring human fetal tissue for "valuable consideration" across state lines, while explicitly allowing "reasonable payments" for transportation, processing, preservation, and storage. The distinction is both legal and ethical. In September 2023, a Cercle accounts manager wrote to UCLA urging the company to be "very careful and clear" that its invoices reflected procurement service fees, not sales — because language implying a sale of tissue, the manager noted, would describe something "illegal to sell." UCLA revised its purchase orders in response.

The pricing pattern is uniform and notable. One order listed seven specimens at $765 each; another covered five at the same rate. David Daleiden of the Center for Medical Progress — whose organization obtained the records — argues the consistency raises questions about whether fees reflected variable costs or a standardized per-specimen charge. Daleiden's history with fetal tissue investigations is long; his 2015 undercover videos involving Planned Parenthood led to a California criminal case against him that was ultimately dismissed and expunged in April 2026.

What the records cannot answer is whether $765 was a reasonable reimbursement or something beyond it. No invoices or cost breakdowns appear in the documents. UCLA redacted researcher names, citing safety concerns, and confirmed the September 2026 production was its final release of non-exempt records. A February 2025 order for liver and brain tissue was later canceled by Cercle, with no indication of whether any transfer occurred.

Neither UCLA nor Cercle responded to requests for comment, and no authority has charged either with violations. The documents establish neither wrongdoing nor innocence — only a company carefully managing its billing language, a university adjusting its paperwork accordingly, and a central question about the true nature of those fees that the available records leave unanswered.

Public records obtained through a California disclosure request reveal that UCLA's medical school paid a tissue procurement company $765 for each individual fetal liver and thymus specimen over a period spanning at least 2023 and into 2025. The payments went to Cercle Allocation Services, a firm that supplies human fetal tissue for biomedical research. The records, which include purchase orders and internal correspondence, show that Cercle itself flagged concerns about how the charges were being described on UCLA's paperwork—specifically worried that the language could be misread as payment for the tissue itself rather than for procurement services.

Federal law draws a sharp line on this question. It prohibits the knowing acquisition or transfer of human fetal tissue for "valuable consideration" if the transaction crosses state lines, though it explicitly permits "reasonable payments" for transportation, processing, preservation, quality control, and storage. The distinction matters legally and ethically. Cercle's internal emails make clear the company understood the stakes. In September 2023, an accounts manager wrote to UCLA that the firm had to be "very careful and clear" about invoicing fees for procurement services, not sales. Language referencing sales tax, the manager noted, would wrongly suggest Cercle was "selling the items received," which the company stated were "illegal to sell." UCLA subsequently revised its purchase orders after Cercle objected to the tax treatment.

The specific transactions in the records show a consistent pattern. One purchase order listed seven specimens at $765 each, totaling $5,355. Another from August 2023 covered five specimens at the same per-unit rate, totaling $3,825. Multiple other orders reflected identical pricing. What makes the uniformity notable, according to David Daleiden of the Center for Medical Progress—the organization that obtained these records—is that it raises questions about whether the charges truly reflected variable procurement costs or instead represented a standardized fee tied to specimen count. Daleiden has long investigated fetal tissue procurement practices; his organization released undercover videos involving Planned Parenthood officials in 2015, work that later made him the subject of a California criminal investigation that was ultimately dismissed and expunged in April 2026.

The records do not contain Cercle's actual invoices or cost breakdowns, making it impossible from the documents alone to determine whether the $765 figure was reasonable reimbursement for legitimate procurement expenses or something else. Cercle characterized the payments as service fees rather than tissue sales, and the correspondence shows the company was acutely conscious of how those payments might be perceived. The UCLA purchase orders identify specimens by organ type, sample number, and date, but do not themselves label the tissue as fetal. Peer-reviewed scientific literature has independently identified Cercle as a source of human fetal liver tissue for researchers, providing external confirmation of the company's business.

UCLA's records show the relationship with Cercle extended into 2025. A February 2025 ticket titled "Liver and brain" was later canceled by Cercle in March, with the company stating it was unable to fulfill the request. The records do not specify whether fetal tissue was involved in that transaction or whether any tissue was ultimately transferred. UCLA redacted the names of researchers from the documents, citing concerns about threats and harassment related to sensitive research. The university said its departments completed their search and that the September 2026 production represented the final batch of non-exempt responsive records.

Neither UCLA nor Cercle responded to requests for comment. No authority has charged either organization with violations in connection with these transactions. The records reviewed do not establish that UCLA or its employees engaged in illegal or unethical conduct, nor do they prove that Cercle violated federal law. What they do show is a company carefully managing the language around its charges, a university revising its paperwork in response, and a set of transactions whose true character—whether permissible reimbursement or something more problematic—remains obscured by the absence of underlying cost documentation. The question of whether the uniform $765 fees represent reasonable procurement expenses or something beyond them remains unanswered.

Due to the nature of our business we must be very careful and clear that we invoice fees for our procurement services.
— Cercle Allocation Services accounts manager, September 2023
The overriding issue is the use of terminology that we must not use due to their improper implication that we are selling taxable items, which we are not.
— Cercle Allocation Services, internal correspondence
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