Why Private Membership Associations Fail FDA Scrutiny

Why Private Membership Associations Fail FDA Scrutiny

April 16, 2026 · 7 min

About this episode

Darshan Kulkarni examines the myth of Private Membership Associations as a loophole to evade FDA scrutiny.

Send us Fan Mail In this episode of the KLF Deep Dive, Darshan Kulkarni deconstructs a persistent and dangerous myth circulating in life sciences and investment circles: the Private Membership Association (PMA). While often marketed as a "contract-based loophole" to evade FDA oversight and civil liability, the reality in federal court is starkly different. Darshan examines the constitutional limits of "freedom of association" and analyzes key case law—including Little v. Q Lasers—to dem...

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