Reproductive Technology in Germany and the United States: An Essay in Comparative Law and Bioethics

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The development of assisted reproductive and genetic screening technologies has produced intense ethical, legal, and policy conflicts in many countries. This Article surveys the German and U.S. experience with abortion, assisted reproduction, embryonic stem cell research, therapeutic cloning, and preimplantation genetic diagnosis. This exercise in comparative bioethics shows that although there is a wide degree of overlap in many areas, important policy differences, especially over embryo and fetal status, directly affect infertile and at-risk couples. This Article analyzes those differences and their likely impact on future reception of biotechnological innovation in each country.