By adopting the ADA Code of Ethics in blanket fashion, the Board is not satisfying its responsibilities, and in light of the recent US Supreme Court opinion in North Carolina Board of Dental Examiners v FTC, raises the specter that the State of Virginia is delegating control over the dental market to a non-sovereign actor and active market participants for anti-competitive purposes. The Board of Dentistry should not adopt the ADA Code of Ethics because it would be giving its authority away to a national organization. If Virginia needs a Code of Conduct, Virginians should develop it. The ADA Code's explanation recognizes ethical obligations often exceed legal duties, stating that the Code is an evolving document and by its very nature cannot be a complete articulation of all ethical [or legal] obligations. The ADA Code is the result of an ongoing dialogue between the dental profession and society, and as such, is subject to continuous review. Although ethics and the law are closely related, they are not the same. Ethical obligations may–and often do–exceed legal duties. Adopting the ADA Code of Ethics and Conduct would be a mistake by the board and the petition for rule making should be defeated