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According to the VAERS website:

"The Vaccine Adverse Event Reporting System (VAERS) is a national early warning system to detect possible safety problems in vaccines used in the United States. VAERS accepts and analyzes reports of adverse events (AEs) after a person has received a vaccination. Anyone can report an adverse event to VAERS. Healthcare professionals are required to report certain adverse events and vaccine manufacturers are required to report all adverse events that come to their attention."

The link: https://vaers.hhs.gov/reportevent.html

The way I read this, if they fail to report adverse events they would be in violation of this requirement.

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