A quantitative text analysis of the petition’s over 10k comments showed that there was an 8-day burst of comments after The Needle’s initial coverage, and that most of the comments added during that period were in opposition to the petition.


Back in March, The Needle reported on an attempt by anti-trans groups to petition the FDA to create a nationwide registry of trans and nonbinary people on estrogen, as well as restrictions on the prescription and administration of estrogen, similar to those on certain forms of testosterone.

Despite this administration’s historic rollbacks to free speech and apparent bias against trans viewpoints, the comments on this petition gave a pleasantly surprising counter to the myth that transphobic governments follow the ‘will of the people’. In fact, over 95% of comments left on the petition opposed restricting estrogen, with the number likely being much higher.

Not only that. According to our analysis, a vast majority of these trans-positive comments left on the petition came from you, the dearly beloved readers of The Needle.

The Needle performed a quantitative analysis of every comment left on the petition, using both traditional analytic methods such as corpus linguistics and other quantitative text methods, as well as our GENDER engine, an in-house tool built specifically for comment analysis.

Our first finding, confirming our suspicions, was that between 96% and 100% of the comments that arrived during the three-day burst after our article on the petition went up (between March 8th and 11th) opposed the proposed estrogen restriction.

Analysis · FDA-2025-P-7321 · 1 of 3

8,672 of 10,033

Comments arrived in the 8-day burst after The Needle's story

11–18 March 2026 (86.4% of the full corpus).2

9,914 of 10,033

Comments oppose the petition, whole corpus

98.8%. Census of tier 4, stratified samples of tiers 0–3.2

95 of 10,033

Comments support the petition, whole corpus

0.9%.2

25 of 10,033

Comments too ambiguous to classify

0.2%.2

We asked you, our audience, to speak out against this transphobic policy, and you listened. It’s moments like these that remind us, even in the darkest of times, that trans dignity has mass public appeal.

Analysis · FDA-2025-P-7321 · 2 of 3

86% of all comments arrived in the 8 days after The Needle's story ran

Daily public comments received on FDA-2025-P-7321, 4 Feb – 18 Aug 2026

Daily comments received on FDA-2025-P-7321, 4 February – 18 August 2026 Daily submissions sit in the single digits through early March, then surge past 1,500 a day in the week after The Needle's 11 March story, accounting for 8,672 of the corpus's 10,033 comments, before falling back to a low trickle through August. 0 500 1,000 1,500 The Needle's story runs, 11 Mar 1,566 (16 Mar) Feb Mar Apr May Jun Jul Aug
Source: daily submission counts, FDA-2025-P-7321 docket, all 10,033 comments.2 The 8-day window (11–18 Mar 2026) is the sharpest volume jump in the corpus; The Needle's initial story on the petition published 11 March 2026. Before that window, the docket received 109 comments across 30 days spanning five weeks.

But a second, and more provocative, finding from our analysis was that the majority of comments in support of the proposed restrictions appear to be organized by the exact same actors that submitted the petition in the first place.

Four separate comments were left on the petition, by commenters with different names and cover letters, each with an identical .docx file attached, formatted as a letter to the FDA commissioner. Investigating the metadata of said file, we found that it was created in a single three-minute editing session by someone named Tim Millea.

Tim Millea, M.D., is not only an orthopedic (rather than a gender) surgeon, but also the Chair of the Health Care Policy Committee for the Catholic Medical Association (CMA). The CMA, according to their own press release, say that they developed the petition and invited medical organizations nationwide”, while also “encouraging its members to sign and submit public documents”. A signed copy of the copy-pasted letter has been archived for public verification.

Prior to The Needle’s coverage, there was an organized wave of support for the petition, initiated by and supported by Tim Millea, the Catholic Medical Association, and others, based off of a copy-pasted “letter of concern.

Then, we ran our article in March, and immediately, a grassroots, mass opposition against the petition began, drowning out the transphobic comments with people’s own voices, annihilating the hate with over 20 times the positivity,and possibly, up to 100 times more.

Some examples of the comments you, our readers (and our readers’ allies) left following our reporting includes scientific takedowns, analyses of ethics violations, and noticing that something isn’t quite right with the first wave of commenters:

One such commenter noticed the logical and evidentiary fallacy of the petition's claims about estrogen being "unsafe".

The petition demands randomized controlled trial (RCT) evidence for benefit while accepting observational cohort data as proof of harm. It's a standard it doesn't apply consistently and that 21 C.F.R. § 201.80(e) doesn't require.

Another presented the actual, in-context numbers for trans women and nonbinary transfemme's actual risk for breast cancer.

It presents relative risks (e.g., a '40-fold increase' in breast cancer) without disclosing that the absolute risk (40 per 100,000) remains significantly lower than the cisgender female baseline (~125 per 100,000) which the FDA recently deemed safe.

A further commenter noticed the fishiness of the comments in support of the petition prior to The Needle's coverage.

…the public comment record purporting to support the petition is substantially the product of a single coordinated advocacy network submitting through multiple organizational vehicles.

Another commenter said that the comments in favor of the petition are somewhat coordinated.

…inflammatory, medically inaccurate, and a scare tactic meant to harm a vulnerable population. Do not listen to the spew of identical comments trying to support this.

This commenter pointed out the hypocrisy and lack of evidence involved in the FDA even considering such a petition.

It is illogical to suggest a month later in December 2025 that another warning be added and a registry created regarding estrogen's safety profile after just declaring it a safe medication.

This commenter pointed out that there is no medical safety issue caused by transfemmes taking estrogen.

There has been no substantial evidence demonstrating that any medical differences between cisgender menopausal women and transgender women would make this molecule harmful to one population and safe for the other, especially given that estrogen is already produced endogenously in both populations.

This collection of comments comes from a smorgasbord of anonymous and identified commenters, from self-identified but anonymous trans people, to various practitioners in the field of medicine, to a biostatistician, to an M.D. with 30 years of experience, to multiple nurses.

One of the comments which shined the most in defense of trans women and nonbinary transfemme’s transition medicine was this one, from someone named John, who appears to be a trans man, included in full below:

Good day! I'm a swimmer, a baker, aspiring epidemiologist of protein disorders! I'm a human being. I brush my teeth and wash my hands. I hug my family before I leave our house! And I also happen to be a transsexual. I read that there is petition to make a list of my trans sisters. This is frightening to compile a list of people because their identity. Trans people move through the world just as all people do. We use our blinkers when we drive, we stand in line at the DMV, wash dishes after dinner, we laugh, we cry, and embrace each other with love. We are human being before we are trans. When people are afraid of trans people they reduce us to what they fear. The point out that trans people sometimes dress differently. That is true trans people wear clothes in a way that celebrates the joy of being themselves. More concerning is when trans people are reduced to our sex lives and medications.
I grew up in a strict catholic community. I was told that being gay or trans made me an ontologically wrong human being. I was told it was better to be a dead child than to be an alive and queer. As one can imagine this broke my heart! How could go through life thinking my own community wanted me to die before they could accept that my life was a little different than theirs? I was so depressed for periods of time I gave up eating because I felt like I was wasting food because I didn't deserve it. Trans people are not new to this world. There have always been people who don't fit into two boxes. When someone is born with anatomy, hormones, or chromosomes that does not fit in these two boxes the term intersex is used by the medical community and the world to describe them.
What a blessing it is to have such a rainbow of anatomy and ways of being! That is what is to be trans or intersex to move through the world differently as ourselves. But people all over the world are not the same and this scares some people. When people hate or are angry at transgender people who want to live more femininely, such as a trans woman or trans fem this is called transmisogyny. It is a way to oppress feminine trans people. A registry of trans women will not keep trans women safe! It is method of doxxing trans women to antagonize, demean, and oppress them. Trans women are deeply affected by this transmisogyny. Just as other women in the U.S. doctors, the law system, and spouses abused and oppress women.
The result of this oppression are that transmisogynist give themselves permission to abuse and murder trans women. Trans women of Color and Indigenous in the United States are murdered at higher rates than anyother queer or trans gender people. The term for the oppression and abuse faced by women who are trans and not white is transmisogynoir. A study by the California HIV AIDS Policy Research center said in their abstract "We conducted secondary analyses of public databases with 229 documented acts of fatal violence against transgender women; Black transgender women accounted for 78.6%. Significantly more Black transgender women were fatally shot by a gun (p = .001) and killed younger (p = .002) than non-Black transgender women. Perpetrators were identified in 54% of cases, among whom 75% were Black cisgender men. Most Black transgender women (64.6%) had romantic/sexual relationships with the perpetrator. Findings call for violence prevention responses that reduce Black transgender women’s vulnerability to violence and engage Black cisgender men seeking intimate relationships with Black transgender women." Compiling a list of trans women will not make anyone safer!
In fact a list of trans women will be used as a hit list for transmisogynist to idenitify new victims to abuse and murder. Transmisogynist are so violent they want to abuse, and murder trans women for existing. We should not make a list that will help abusers target trans women. Trans women need safety, love, and protections to keep her alive!! A safer world for trans women is one in which they are not registered on a list. Let us create a world where trans women are safe and treated equally as humans. My trans sisters deserve to be safe and grow old with us! trans misogynists also target medication that is used to treat endocrine disorders. Many false claims are used to make this medication seem scary, harmful or morally wrong.
But the same estrogen my Mom uses is for menopause same estrogen a trans women use. It is not chemically different. There are certain percautions before taking estrogen as with all medications. But the result of this medication does not hurt a body no matter your organs systems. Estrogen is a medication. If a medication can help a woman go through life happy and healthy it is positive!
When people are allowed to be openly trans women or trans fem and are safe they will feel less depressed. Being openly trans saves lives! Just as being openly gay! Lets save lives! Lets be kind and keep trans women safe! Save lives protect all women!

On balance, the most accurate extrapolation from this data, using our in-house analysis engine, is that 99.4% of comments received on the day of The Needle’s coverage and in the week that followed were in opposition to the FDA petition.

To clarify, when we re-ran the engine to extrapolate the data for the entire corpus rather than just that eight-day period, the numbers did change somewhat.

The results of the full-corpus analysis were that 98.8% of the comments on the petition oppose its proposition, 0.9% of the comments are in favor, and the remaining 0.2% of the corpus was statistically “too ambiguous to call.” Even generously placing that 0.2% with the transphobes, 98.8% of comments on a specifically transphobic petition being strongly trans-positive is a wonderful result.

Using our in-house analysis engine, the most accurate extrapolation from this data is that 99.4% of comments received on the day of The Needle’s coverage and in the week that followed were in opposition to the FDA petition.

To clarify, when we re-ran the engine to extrapolate the data for the entire corpus rather than just that eight-day period, the numbers did change somewhat.

The results of the full-corpus analysis were that 98.8% of the comments on the petition oppose its proposition, 0.9% of the comments are in favor, and the remaining 0.2% of the corpus was statistically “too ambiguous to call.” Even generously placing that 0.2% with the transphobes, 98.8% of comments on a specifically transphobic petition being strongly trans-positive is a wonderful result.

Analysis · FDA-2025-P-7321 · 3 of 3

Nearly 99 of every 100 comments on the petition oppose it

Stance composition, all 10,033 comments on FDA-2025-P-7321

Stance composition of all 10,033 comments on FDA-2025-P-7321 9,914 of 10,033 comments, 98.8%, oppose the petition. 95 comments, 0.9%, support it. 25 comments, 0.2%, could not be classified. Oppose: 98.8% Support 95 (0.9%) Ambiguous 25 (0.2%)
Oppose the petition Support the petition Too ambiguous to classify
Source: stage-two human adjudication (full census of the 367 tier-4 comments; stratified samples of tiers 0–3), weighted to the whole corpus.2 This is the whole-corpus estimate, not a burst-window-only figure; see the methodology note for what this data package can and can't isolate by date.

Anti-trans politics, once again, aren’t popular, and they aren't supported by the will of the people. They are an engineered phenomenon by a vocal minority of deep-pocketed bigots who either are, or tend to flock with, literal fascists. And it’s thanks to work by The Needle and other journalistic organizations that we can prove, time and time again, that money and hatred cannot be used to cover up stupidity, or replace the human desire for justice.

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A note on our methodology: We used deterministic quantitative text analysis methods, including our house-built GENDER-engine, to reach these exact numbers. GENDER was built by Editor-in-Chief Artemis Douglas to assess anti-trans and anti-gender politics and its mechanisms through textual data.

Analysis · FDA-2025-P-7321 · Methodology

How we did this

Question

How much of the comment volume on FDA-2025-P-7321, which asks the FDA for a Boxed Warning and, per several comments, a REMS patient registry on off-label estrogen prescribing in natal males1, arrived after The Needle's initial coverage, and what was the stance composition of the full comment corpus?

Period

All comments received on the docket, 4 February 2026 – 18 August 2026.

Definitions

Burst window
The 8 consecutive days, 11–18 March 2026, with the sharpest jump in daily submission volume in the corpus. The Needle's initial story on the petition published 11 March 2026.
Concern tier (0–4)
The GENDER-engine's score for density of engagement with the petition's own proposed registry/warning vocabulary: not a hostility score. Comments that oppose the petition and quote or rebut its language at length can score as high as, or higher than, comments that support it.
Stance
Whether a comment supports, opposes, or is ambiguous about the petition, established by direct human reading, stage-two adjudication for tiers 2–4 and a separate stratified read for tiers 0–1, not by the engine's tier score.

Steps

  1. Ran the GENDER-engine (anti-gender pack, balanced dial, full mode) over all 10,033 comments; 5,929 scored above the emission threshold (tiers 2–4).
  2. Pulled daily submission counts for all 10,033 comments and identified the 8-day window with the sharpest volume jump.
  3. Drew a stratified sample of 597 comments for human stage-two adjudication: a full census of the 367 tier-4 comments, plus samples of 150 (of 2,821) tier-3 and 80 (of 2,741) tier-2 comments.
  4. Separately hand-read a 200-comment stratified sample of the below-threshold tiers 0–1 for stance, since the engine's emission threshold does not sort on stance.
  5. Combined the census and sample estimates, weighted by stratum population, into the whole-corpus stance composition reported in the second visualization.

What we excluded

  • A regex-based "explicit support/oppose phrasing" check (576 comments) is not used for the stance composition figures. A post-delivery audit found 144 of its 197 support-side matches were negations: "I do NOT support this petition," inflating its apparent support count roughly three- to four-fold. It remains useful for comparing engine-score patterns between the two stances, but not as a headline composition number.
  • Tier-3 and tier-2 keep rates from the 25-comment hostile-core adjudication are not extrapolated to their full populations (5.3% and 2.9% sampled, respectively); the sample sizes are too small to support a reliable full-population estimate.

Limitations

  • This data package does not link individual comments' dates to their adjudicated stance, so a burst-window-only oppose percentage can't be recomputed from it; only the whole-corpus figure (98.8%) can be shown at full census/sample fidelity here.
  • "Actor-mention" codes (for example, a document naming a hostile actor) fire whenever a comment mentions a named actor, regardless of whether the comment endorses or opposes them. They do not by themselves establish that the same people organized both the petition and the comments supporting it, so that claim is not charted in this piece.
  • Two scoring-rule defects were confirmed in adjudication and affect the raw engine tier/tactic counts, not the hand-read stance composition: a rule intended to catch administrative obfuscation matched the word "guidance" even on documents where that word does not appear (unsupported in all 34 sampled cases), and a rule intended to catch pseudo-clinical framing fired on the plain clinical term "gender-affirming care" with no delegitimizing marker present (unsupported in 251 of 265 sampled non-hostile-core cases; it did not misfire on any of the 25 confirmed hostile-core comments).

Verification

Stance and hostile-core status were both established by direct human reading against the full comment text, independent of the engine's raw tier score.

Data and code

Underlying register and corpus files available on request from the newsroom.

What we are not publishing

  • The names of every individual comment submitter. A handful of organizations and publicly identified advocates appear in the underlying data; private individuals who filed a public comment are not named here: a public docket entry is not consent to be singled out in a news graphic.

Sources

  1. Citizen Petition FDA-2025-P-7321-0001 (Schwartz, et al.), requesting an FDA Boxed Warning and REMS patient registry on off-label estrogen prescribing in natal males. Regulations.gov. Archived copy. Record · archived 23 Aug 2026 · primary
  2. The Needle's analysis of the FDA-2025-P-7321 comment corpus: the full public comment record (10,033 comments) obtained from the docket, daily submission counts, and the GENDER-engine run (anti-gender pack, balanced dial, full mode) over that record, with stage-two human adjudication of a stratified 597-comment sample and a supplementary 200-comment stance read of the below-threshold tiers. Analysis · in-house · primary