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                                                                    EXHIBIT 14.1

                                                              ADOPTED 12/17/2003

                              HEALTHGATE DATA CORP.

                       CODE OF BUSINESS CONDUCT AND ETHICS


Introduction

          This Code of Business Conduct and Ethics covers a wide range of
business practices and procedures. It does not cover every issue that may arise,
but it sets out basic principles to guide all employees of the Company. All of
our employees must conduct themselves accordingly and seek to avoid even the
appearance of improper behavior.

          If a law conflicts with a policy in this Code, you must comply with
the law. If you have any questions about these conflicts, you should ask your
supervisor how to handle the situation.

          Those who violate the standards in this Code will be subject to
disciplinary action, up to and including termination of employment. If you are
in a situation which you believe may violate or lead to a violation of this
Code, follow the guidelines described in Section 14 of this Code.

1.   Compliance with Laws, Rules and Regulations

          Obeying the law, both in letter and in spirit, is the foundation on
which this Company's ethical standards are built. All employees must respect and
obey the laws of the cities, states and countries in which we operate. Although
not all employees are expected to know the details of these laws, it is
important to know enough to determine when to seek advice from supervisors,
managers or others.

2.   Conflicts of Interest

          A "conflict of interest" exists when a person's private interest
interferes in any way with the interests of the Company. A conflict situation
can arise when an employee, officer or director takes actions or has interests
that may make it difficult to perform his or her Company work objectively and
effectively. Conflicts of interest may also arise when an employee, officer or
director, or members of his or her family, receives improper personal benefits
as a result of his or her position in the Company.

          Conflicts of interest may not always be clear-cut, so if you have a
question, you should consult with higher levels of management or the Company's
Legal Counsel. Any employee, officer or director who becomes aware of a conflict
or potential conflict should bring it to the attention of a supervisor, manager
or other appropriate personnel or consult the procedures described in Section 14
of this Code.

          Follow these guidelines in avoiding conflicts of interest. If other
situations arise that are not addressed directly here, you should consult with
your supervisor or the Company's Legal Counsel (Stephen M. Kane, Esq. of the
Boston law firm Rich May, a Professional Corporation. Mr. Kane can be reached at
617 556-3800 or skane@richmaylaw.com).

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Relationships with Competitors - If you are an employee, officer, or director:
                 -   Do not work for, consult to, advise, or perform any
                     services for a competitor.
                 -   Do not purchase or maintain a financial interest in any
                     direct competitors unless your ownership interest is
                     passive and equals less that 5% of the competitor.

Relationship with Customers and Vendors

          IF YOU ARE AN EMPLOYEE OR OFFICER (INCLUDING EMPLOYEE-DIRECTORS):
                 -   Do not work for, consult to, advise, or perform any
                     services for any company or institution that is a vendor or
                     customer to the Company (unless you are providing such
                     services on HealthGate's behalf).
                 -   Do not have any written or oral, formal or informal "side
                     agreements" with any customer or vendor. In order to assure
                     proper accounting and disclosure is maintained, all
                     agreements with customers and vendors must be documented
                     and reviewed by the Chief Financial Officer.
                 -   You may serve as a director of a company that is a vendor
                     or customer to HealthGate under the following
                     circumstances:
                        1.  You disclose your appointment as a director to
                            HealthGate's Legal Counsel, who in turn obtains the
                            CEO's written approval (or, in the case of an
                            executive officer of HealthGate, the Legal Counsel
                            obtains approval from the Board of Directors); and
                        2.  You agree to recuse yourself from (i.e., refrain
                            from participating in or influencing, directly or
                            indirectly) any matter affecting the business
                            relationship or transactions between HealthGate and
                            the customer or vendor for which you are a director.
          IF YOU ARE A OUTSIDE DIRECTOR (I.E. NON-EMPLOYEE DIRECTOR):
                 -   You may work for, consult to, advise, serve on the Board of
                     Directors, or perform services for a company or institution
                     that is a vendor or customer HealthGate only if:
                        1.  Your relationship with the customer or supplier is
                            disclosed to HealthGate's Legal Counsel and
                            HealthGate's Board of Directors; and
                        2.  You agree to recuse yourself from (i.e., refrain
                            from participating in or influencing, directly or
                            indirectly) any matter affecting the business
                            relationship or transactions between HealthGate and
                            the customer or vendor.

3.   Insider Trading

          Employees who have access to confidential information are not
permitted to use or share that information for stock trading purposes or for any
other purpose except the conduct of our business. All non-public information
about the Company should be considered confidential information. To use
non-public information for personal financial benefit or to "tip" others who
might make an investment decision on the basis of this information is not only
unethical but also illegal. In order to assist with compliance with laws against
insider trading, the Company has adopted a specific policy entitled "Insider
Trading, Black-Out Periods and Confidentiality" governing employees' trading in
securities of the Company. This policy has been distributed to every employee.
If you have any questions, please consult HealthGate's Chief Financial Officer
or Legal Counsel.

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4.   Corporate Opportunities

          Employees, officers and directors are prohibited from taking for
themselves personally opportunities that are discovered through the use of
corporate property, information or position without the consent of the Board of
Directors. No employee may use corporate property, information, or position for
improper personal gain, and no employee may compete with the Company directly or
indirectly. Employees, officers and directors owe a duty to the Company to
advance its legitimate interests when the opportunity to do so arises.

5.   Competition and Fair Dealing

          We seek to outperform our competition fairly and honestly. Stealing
proprietary information, possessing trade secret information that was obtained
without the owner's consent, or inducing such disclosures by past or present
employees of other companies is prohibited. Each employee should endeavor to
respect the rights of and deal fairly with the Company's customers, suppliers,
competitors and employees. No employee should take unfair advantage of anyone
through manipulation, concealment, abuse of privileged information,
misrepresentation of material facts, or any other intentional unfair-dealing
practice.

     The purpose of business entertainment and gifts in a commercial setting is
to create good will and sound working relationships, not to gain unfair
advantage with customers. No gift or entertainment should ever be offered,
given, provided or accepted by any Company employee, family member of an
employee or agent unless it: (1) is not a cash gift, (2) is consistent with
customary business practices, (3) is not excessive in value, (4) cannot be
construed as a bribe or payoff and (5) does not violate any laws or regulations.
Please discuss with HealthGate's Chief Financial Officer any gifts or proposed
gifts which you are not certain are appropriate.

6.   Discrimination and Harassment

          The diversity of the Company's employees is a tremendous asset. We are
firmly committed to providing equal opportunity in all aspects of employment and
will not tolerate any illegal discrimination or harassment of any kind. Examples
include derogatory comments based on racial or ethnic characteristics and
unwelcome sexual advances. The Company has a separate Non-Harassment Policy that
has been distributed to all employees.

7.   Health and Safety

          The Company strives to provide each employee with a safe and healthy
work environment. Each employee has responsibility for maintaining a safe and
healthy workplace for all employees by following safety and health rules and
practices and reporting accidents, injuries and unsafe equipment, practices or
conditions.

          Violence and threatening behavior are not permitted. Employees should
report to work in condition to perform their duties, free from the influence of
illegal drugs or alcohol. The use of illegal drugs in the workplace will not be
tolerated.

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8.   Record-Keeping

          The Company requires honest and accurate recording and reporting of
information in order to make responsible business decisions. For example, only
the true and actual number of hours worked should be reported.

          Many employees regularly use business expense accounts, which must be
documented and recorded accurately. If you are not sure whether a certain
expense is legitimate, ask your supervisor or HealthGate's Chief Financial
Officer.

          All of the Company's books, records, accounts and financial statements
must be maintained in reasonable detail, must appropriately reflect the
Company's transactions and must conform both to applicable legal requirements
and to the Company's system of internal controls. Unrecorded or "off the books"
funds or assets should not be maintained unless permitted by applicable law or
regulation and expressly disclosed to and approved by both the Chief Executive
Officer and the Chief Financial Officer.

          Business records and communications often become public, and we should
avoid exaggeration, derogatory remarks, guesswork, or inappropriate
characterizations of people and companies that can be misunderstood. This
applies equally to e-mail, internal memos, and formal reports. Records should
always be retained or destroyed according to the Company's record retention
policies. In accordance with those policies, in the event of litigation or
governmental investigation please consult the Company's CEO or Legal Counsel

9.   Confidentiality

          Employees must maintain the confidentiality of confidential
information entrusted to them by the Company or its customers, except when
disclosure is authorized by the CEO or the Company's Legal Counsel or required
by laws or regulations. Confidential information includes all non-public
information that might be of use to competitors, or harmful to the Company or
its customers, if disclosed. It also includes information that suppliers and
customers have entrusted to us. The obligation to preserve confidential
information continues even after employment ends. In connection with this
obligation, every employee should have received the Company's separate policy on
"Insider Trading, Black-Out Periods and Confidentiality" and executed a
proprietary information agreement when he or she began his or her employment
with the Company.

10.  Protection and Proper Use of Company Assets

          All employees should endeavor to protect the Company's assets and
ensure their efficient use. Theft, carelessness, and waste have a direct impact
on the Company's profitability. Any suspected incident of fraud or theft should
be immediately reported for investigation. Company equipment should not be used
for non-Company business, though incidental personal use may be permitted.

          The obligation of employees to protect the Company's assets includes
its proprietary information. Proprietary information includes intellectual
property such as trade secrets, patents, trademarks, and copyrights, as well as
business, marketing and service plans, customer and prospective customer lists,
engineering and manufacturing ideas, designs, databases, records, salary
information

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and any unpublished financial data and reports. Unauthorized use or distribution
of this information would violate Company policy. It could also be illegal and
result in civil or even criminal penalties.

11.  Payments to Government Personnel

          The U.S. Foreign Corrupt Practices Act prohibits giving anything of
value, directly or indirectly, to officials of foreign governments or foreign
political candidates in order to obtain or retain business. It is strictly
prohibited to make illegal payments to government officials of any country.

          In addition, the U.S. government has a number of laws and regulations
regarding business gratuities which may be accepted by U.S. government
personnel. The promise, offer or delivery to an official or employee of the U.S.
government of a gift, favor or other gratuity in violation of these rules would
not only violate Company policy but could also be a criminal offense. State and
local governments, as well as foreign governments, may have similar rules. The
Company's CFO or Legal Counsel can provide guidance to you in this area.

12.  Waivers of the Code of Business Conduct and Ethics

          Any waiver of this Code for executive officers or directors may be
made only by the Board of Directors and will be promptly disclosed as required
by law or stock exchange regulation.

13.  Reporting any Illegal or Unethical Behavior

          Employees are encouraged to talk to supervisors, managers or other
appropriate personnel about observed illegal or unethical behavior and when in
doubt about the best course of action in a particular situation. It is the
policy of the Company not to allow retaliation for reports of misconduct by
others made in good faith by employees. Employees are expected to cooperate in
internal investigations of misconduct. For more information, please refer to the
employee handbook.

          Additionally, employees may, in confidence and anonymously, at any
time contact Company's Legal Counsel, Stephen M. Kane, Esq., with the Boston law
firm of Rich May, a Professional Corporation, at 617-556-3800 or
skane@richmaylaw.com to discuss or report any illegal or unethical behavior or
any concern regarding questionable accounting or auditing matters without fear
of dismissal or retaliation of any kind.

14.  Compliance Procedures

          We must all work to ensure prompt and consistent action against
violations of this Code. However, in some situations it is difficult to know if
a violation has occurred. Since we cannot anticipate every situation that will
arise, it is important that we have a way to approach a new question or problem.
These are the steps to keep in mind:

          -   MAKE SURE YOU HAVE ALL THE FACTS. In order to reach the right
              solutions, we must be as fully informed as possible.

          -   ASK YOURSELF: WHAT SPECIFICALLY AM I BEING ASKED TO DO? DOES IT
              SEEM UNETHICAL OR

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              IMPROPER? This will enable you to focus on the specific question
              you are faced with, and the alternatives you have. Use your
              judgment and common sense; if something seems unethical or
              improper, it very well may be.

          -   CLARIFY YOUR RESPONSIBILITY AND ROLE. In most situations, there is
              shared responsibility. Are your colleagues informed? It may help
              to get others involved and discuss the problem.

          -   DISCUSS THE PROBLEM WITH YOUR SUPERVISOR. This is the basic
              guidance for all situations. In many cases, your supervisor will
              be more knowledgeable about the question, and will appreciate
              being brought into the decision-making process. Remember that it
              is your supervisor's responsibility to help solve problems.

          -   SEEK HELP FROM COMPANY RESOURCES. In the rare case where it may
              not be appropriate to discuss an issue with your supervisor, or
              where you do not feel comfortable approaching your supervisor with
              your question, discuss it with the Human Resources manager or
              Company's Legal Counsel (Stephen M. Kane, Esq. at (617) 556-3800
              or skane@richmaylaw.com).

          -   YOU MAY REPORT ETHICAL VIOLATIONS IN CONFIDENCE AND WITHOUT FEAR
              OF RETALIATION. If your situation requires that your identity be
              kept secret, your anonymity will be protected. The Company does
              not permit retaliation of any kind against employees for good
              faith reports of ethical violations.

          -   ALWAYS ASK FIRST, ACT LATER: If you are unsure of what to do in
              any situation, seek guidance BEFORE YOU ACT.

          -   The Board of Directors shall determine, or designate appropriate
              persons to determine, appropriate actions to be taken in the event
              of violations of the Code of Business Conduct and Ethics. Such
              actions shall be reasonably designed to deter wrongdoing and to
              promote accountability for adherence to the Code of Business
              Conduct and Ethics and to these additional procedures, and shall
              include written notices to the individual involved that the Board
              has determined that there has been a violation, censure by the
              Board, demotion or re-assignment of the individual involved,
              suspension with or without pay or benefits (as determined by the
              Board) and termination of the individual's employment. In
              determining what action is appropriate in a particular case, the
              Board of Directors shall take into account all relevant
              information, including the nature and severity of the violation,
              whether the violation was a single occurrence or repeated
              occurrences, whether the violation appears to have been
              intentional or inadvertent, whether the individual in question had
              been advised prior to the violation as to the proper course of
              action and whether or not the individual in question had committed
              other violations in the past.

15.  Additional Policies and Procedures for Chief Executive Officer and Senior
     Financial Officers

          The CEO and all senior financial officers, including the CFO,
principal accounting officer and controller, are subject to the following
additional specific policies and procedures:

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          -   The CEO and all senior financial officers are responsible for
              full, fair, accurate, timely and understandable disclosure in the
              periodic reports required to be filed by the Company with the SEC.
              Accordingly, it is the responsibility of the CEO and each senior
              financial officer promptly to bring to the attention of the
              Disclosure Committee any material information of which he or she
              may become aware that affects the disclosures made by the Company
              in its public filings and to otherwise assist the Disclosure
              Committee in fulfilling its responsibilities.

          -   The CEO and each senior financial officer shall promptly bring to
              the attention of the Disclosure Committee and the Audit Committee
              any information he or she may have concerning (a) significant
              deficiencies in the design or operation of internal controls which
              could adversely affect the Company's ability to record, process,
              summarize and report financial data or (b) any fraud, whether or
              not material, that involves management or other employees who have
              a significant role in the Company's financial reporting,
              disclosures or internal controls.

          -   The CEO and each senior financial officer shall promptly bring to
              the attention of the Company's Legal Counsel and the CEO and to
              the Audit Committee any information he or she may have concerning
              any violation of the Company's Code of Business Conduct and
              Ethics, including any actual or apparent conflicts of interest
              between personal and professional relationships, involving any
              management or other employees who have a significant role in the
              Company's financial reporting, disclosures or internal controls.

          -   The CEO and each senior financial officer shall promptly bring to
              the attention of the Legal Counsel and the CEO and to the Audit
              Committee any information he or she may have concerning evidence
              of a material violation of the securities or other laws, rules or
              regulations applicable to the Company and the operation of its
              business, by the Company or any agent thereof, or of violation of
              the Code of Business Conduct and Ethics.

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