Exhibit 14.1
  (HLTH LOGO)

(WEBMD LOGO)   HLTH
    Corporation and WebMD Health Corp.
  Code of
    Business Conduct
  Revised
    April 2009
            Wayne T. GattinellaChief Executive Officer, WebMD Health Corp.
  Martin J.
    Wygod
 Chairman of the Boards of Directors of HLTH
 Corporation and WebMD Health Corp. and Acting CEO of HLTH Corporation




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I. GENERAL
    STATEMENT OF POLICY
  Our
    policy is to conduct business in an honest and ethical manner
    and in accordance with the laws that apply to us
  1
  
    to foster proper business conduct and ethical decision-making,
    to prevent unethical or unlawful behavior and to stop any such
    behavior as soon as reasonably possible after its discovery.  We
    expect you to follow this Code of Conduct and to report any
    violations you become aware of
    
    is responsible for his or her own actions with respect to proper
    business conduct and behavior, and
    if he or she sees or becomes aware of unethical or unlawful
    activity, is obligated to report such activity immediately to
    the Compliance Officer for this Code of Conduct (described in
    Section III.C. below), to the appropriate General Counsel,
    to the Chief Financial Officer or to one of the senior officers
    in our Human Resources Department.    2
  Violations
    of this Code of Conduct will lead to disciplinary
    action
    Violations
    of our other policy statements may also be a violation of this
    Code of Conduct
    
    the Policy Regarding Insider Trading, Tipping and Other Wrongful
    Disclosures,
    the Communications Policy,
    the Electronic Communications Policy,    1 References

    to the Companies (or we, our
    or similar pronouns) in this Code of Conduct mean HLTH
    Corporation and all of its subsidiary companies (including WebMD
    Health Corp. and all of its subsidiary companies).
 2 References

    to the terms employee and personnel, as
    used throughout this Code of Conduct, are generally intended to
    include  in addition to directors, officers and
    employees (full-time and part-time) of the Companies 
    contractors, consultants and similar persons providing services
    at the direction of the Companies. In some cases, implementation
    of the principles contained in this Code of Conduct may be
    different for third party service providers, depending on the
    scope and nature of the services provided. For example, certain
    conflicts of interest that would not be acceptable
    for an employee may be acceptable for a contractor, depending on
    the nature of the specific relationship. Please consult the
    Legal Department or the Compliance Officer for guidance.
  Code of Business
    Conduct  Page 2




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
    the HIPAA Privacy Policies, and
    the Employee Handbook.     USE GOOD JUDGMENT  DONT IGNORE YOUR
    INSTINCTS
  FOUR
    QUESTIONS TO ASK YOURSELF BEFORE ACTING:
  
    Will my actions meet the letter of the law or rule but
    violate its spirit?
    Would my failing to act make the situation worse or allow
    a wrong to continue?
    How would my actions look if they were reported on the
    front page of the newspaper?
    Would we lose customers if my actions were known to
    them?  FOUR
    WARNING SIGNS. If you hear yourself or someone else
    say:
  
    Everybody does it
    Maybe just this once
    No one will ever know
    It wont matter in the end  STOP and think through the situation carefully, seek
    guidance, and take the time necessary to reach the right
    result.
   Code of Business
    Conduct  Page 3




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II. GUIDELINES
    FOR EMPLOYEE CONDUCT
     How to Get Your Questions
    Answered
  Whenever you have questions about the requirements of this
    Code of Conduct or how they apply to your job, you should call
    one or more of the following persons:
  
    your manager or supervisor,
    the head of your business unit or department,
    your Human Resources manager or other members of our HR
    Department,
    the Compliance Officer, and
    the appropriate General Counsel (of either HLTH or WebMD) or
    other members of the Legal Department.
  In addition, for questions relating to financial reporting,
    accounting and related matters, you may contact the Chief
    Financial Officer of HLTH and WebMD or other members of the
    Finance Departments of HLTH and WebMD.
  Selected
    Contact Information
  Our Compliance Officer is Lewis Leicher, an Assistant General
    Counsel. He can be reached at
    858-759-6008
    or lleicher@webmd.net.
  HLTHs General Counsel is Charles Mele. He can be
    reached at
    201-703-3426
    or cmele@hlth.com. WebMDs General Counsel is Doug Wamsley.
    He can be reached at
    212-624-3862
    or dwamsley@webmd.net.
  HLTHs and WebMDs Chief Financial Officer is Mark
    Funston. He can be reached at
    201-398-2653
    or 212-624-3764 or mfunston@webmd.net.
  In Human Resources, you can contact:  Patricia
    White at 212-624-3851 or pwhite@webmd.net; or, for Porex,
    Rod Shough at 770-515-7730 or rod.shough@porex.com.
  Our Human Resources counsel is Anne Smith. She can be reached
    at
    201-703-3427
    or asmith@hlth.com.
  Our Chief Technology Officer, who is also our Chief Security
    Officer, is William Pence. He can be reached at
    646-674-5315
    or wpence@webmd.net.
  Our Chief Privacy Officer is Matt Kaminer. He can be reached
    at
    212-624-3745
    mkaminer@webmd.net.
    Code of Business
    Conduct  Page 4




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A.
    You
    may not use funds or assets of the Companies for any unlawful or
    unethical purpose or for personal gain    
    Our policy is to forgo any business that can be obtained
    only by making improper or illegal payments or kickbacks  
    No payment or gift shall be offered or made to a government
    official to influence any discretionary decision by such person
    in his or her official capacity. Should any such gifts or
    payments be requested, our Legal Department should be contacted
    immediately. Giving any gifts  even gifts or
    entertainment of nominal value  to government
    officials is highly regulated and often illegal.
    No payment shall be offered or made to an employee or
    representative of an existing or potential customer or other
    business partner to influence any business decision by such
    person. Should any such payments be requested, our Legal
    Department or the Compliance Officer should be contacted
    immediately.  n
    In circumstances where it would not violate any other policy of
    the Companies and would not create an appearance of impropriety
    or be considered a business inducement, you may provide
    non-monetary gifts or entertainment in accordance with the
    policies and procedures and monetary limits applicable to your
    business unit and job responsibilities. In general, such gifts
    or entertainment must be of nominal value.n
    Business meals with customers or other business partners are
    permitted and expenses for those meals will be reimbursed in
    accordance with applicable expense reimbursement policies.  
    Subterfuge of any kind in making payments or other use of
    the assets of the Companies is forbidden  
    No payment by a third party on behalf of the Companies may be
    authorized with the intention that any part of it is to be used
    for any unlawful purpose.
    No payment or other use of assets or funds by the Companies may
    be offered or made for a purpose other than that described by
    the records supporting the payment.  
    You may not accept payments or gifts that obligate you
    with respect to matters relating to our business or that create
    an appearance your decision-making would be improperly
    influenced  
    Gifts of any type or amount may never be solicited from
    suppliers, customers or other business partners.
    Any form of a gift that may obligate one of our employees to act
    in a particular manner with regard to our business is a bribe
    and is not allowed, regardless of its value. In addition, you
    may not accept cash gifts, regardless of amount.  n
    If a supplier, customer or other business partner offers you a
    bribe, kickback or other improper payment, you should report the
    attempt to the Compliance Officer, to the appropriate General
    Counsel or to the Chief Financial Officer.n
    You may accept gifts of nominal value ordinarily used for sales
    promotion (for example, calendars, appointment books, pens,
    etc.) and may accept other gifts consistent with local social
    and business custom if reasonable in cost and frequency and
    reported to your supervisor.  
    Ordinary business lunches or reasonable
    entertainment consistent with local social and business custom
    is also permissible if reasonable in cost and frequency.    Code of Business
    Conduct  Page 5




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
    Do not advance your personal interests at the expense of
    the Companies  
    You may not take for yourself any opportunity for financial gain
    that you find out about because of your position at any of the
    Companies or through the use of property or information of any
    of the Companies, unless the Chief Executive Officers of each of
    HLTH and WebMD have made a decision to forego the opportunity
    (after seeking approval of the applicable Board of Directors if
    needed).
    See below, under Conflicts of Interest Policy for
    additional policies that apply.  
    Protect the property and assets of the Companies and
    ensure their proper use  
    Employees must protect property and assets of the Companies from
    loss, waste, damage or theft and must use them only for
    legitimate business purposes.  n
    Assets of the Companies include funds, investments, facilities,
    equipment, proprietary or confidential information, technology,
    business plans, ideas for new products and services, trade
    secrets, inventions, copyrightable materials and client lists.n
    Unless otherwise prohibited by an employees supervisor,
    limited and reasonable incidental use of telephone, computer or
    similar equipment of the Companies is permitted, so long as it
    does not interfere with business use and is in compliance with
    all other applicable policies of the Companies.n
    Charitable donations of cash, assets or services of the
    Companies can only be made if approved by HLTHs or
    WebMDs Chief Executive Officer, Chief Financial Officer or
    General Counsel or WebMDs Chief Operating Officer and the
    required approval must be sought prior to making any commitment
    with respect to any such donation.  
    Any employee found to be engaging in, or attempting, theft of
    any property of any of the Companies or any personal property of
    other employees will be subject to termination and possible
    civil and criminal proceedings. All employees have a
    responsibility to report any theft or attempted theft to
    appropriate management.
    See below, under Section II.F., Protection of
    Proprietary Information for additional policies that apply.  B.
    Conflicts
    of Interest Policy  1.
    Failure
    to disclose a conflict of interest is a violation of this Code
    of Conduct      Code of Business
    Conduct  Page 6




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2.
    Your
    business dealings on behalf of the Companies should not be
    influenced, or appear to be influenced, by your personal
    interests or your relationships with others        3.
    The
    following are examples of conflict of interest
    situations:    
    Financial interests in competitors, customers, vendors, or
    contractors.  Where an employee, close
    relative (such as a member of his or her family, household,
    in-laws, etc.), or any other person with whom the employee has a
    close personal relationship, has a direct or indirect financial
    interest in an organization which does business with or is a
    competitor of one or more of the Companies, a conflict of
    interest may exist. Such a conflict is unlikely if the financial
    interest consists of holdings of less than one percent of any
    class of securities in a widely held corporation listed on a
    recognized stock exchange, or regularly traded on an
    over-the-counter
    market, or if our transactions with that corporation would not
    tend to either affect the value of such securities or contribute
    materially to its earnings. However, depending on the
    circumstances, a conflict of interest might exist, even if the
    amount of holdings in such corporation is less than one percent,
    where the employee is in a position to control or influence our
    decisions or actions with respect to a transaction with such
    corporation. In addition, if the investment or interest by the
    employee, close relative, or any other person with whom the
    employee has a close personal relationship, is in a small
    organization doing business with us, a conflict of interest is
    likely in view of the possible relative importance of the
    transaction to such an organization.
    Serving in the management of customers, vendors,
    contractors, or competitors.  Where an
    employee serves as director, officer, or in any other management
    or consulting capacity with, or renders other services to
    another organization which does or is seeking to do business
    with us, or which is a competitor, a conflict of interest will
    normally exist.
    Transactions with contractors, customers, or vendors of
    the Companies.  Where an employee, a close
    relative of the employee, or any other person with whom the
    employee has a close personal relationship, buys, sells, or
    leases (other than on behalf of the Companies) any kind of
    property, facilities, services, or equipment from or to any
    person or organization which is, or is seeking to become, a
    contractor, customer, or vendor of the Companies, a conflict of
    interest may arise.  
    A conflict would not normally exist, however, in cases of
    routine personal purchases, sales, or leases made in the
    ordinary course from or to a large established company, such as
    for the employees personal household needs.
    On the other hand, if the employee, as part of his or her job
    responsibilities for us, is in a position to make or influence
    decisions pertaining to transactions with such a company, a
    potential conflict of interest might exist, depending on the
    circumstances, if he or she has any private transactions with
    that company.  Code of Business
    Conduct  Page 7




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
    Transactions with the Companies.  Any
    proposed business transaction between any of the Companies and
    an employee of any of the Companies (other than those relating
    to the employees employment or services as an employee),
    or a close relative of an employee, or any other person with
    whom the employee has a close personal relationship would
    generally involve or lead to a conflict and must be fully
    disclosed to appropriate management in advance and requires
    approval by the Legal Department or, in the case of a director,
    executive officer or Senior Financial Officer of HLTH or WebMD,
    approval of the Audit Committee of the applicable company. The
    officers who are Senior Financial Officers of each
    of HLTH and WebMD for purposes of this Code of Conduct are the
    principal financial officer, comptroller or principal accounting
    officer and persons performing similar functions of that company.
    Corporate Opportunity.  Where an
    employee, a close relative of the employee, or any other person
    with whom the employee has a close personal relationship
    participates in any personal venture or transaction involving
    any existing or potential business activity or opportunity  
    in which any of the Companies has an expressed interest or
    is of the type that any of the Companies would be expected to
    consider      C.
    Policy
    Regarding Financial Reporting and Recordkeeping and Related
    Internal Controls    1.
    Unauthorized
    transactions and illegal or improper recordkeeping are not
    permitted  
    Business transactions shall be reported promptly and accurately
    in order to permit the preparation of accurate financial and
    other records.
    Business transactions shall be executed only by employees
    authorized to do so.
    Business transactions shall be evidenced by full and complete
    written agreements in accordance with policies and procedures
    approved by the Legal Department and the Finance Department.
    Acquisitions or dispositions of assets and other transactions
    are permitted only with authorization by the appropriate
    management levels.
    Employees are prohibited from knowingly making untrue or
    misleading statements to our independent auditors or internal
    auditors or causing anyone else to do so and no employee may
    seek to improperly influence, directly or indirectly, the
    auditing of our financial records.  Code of Business
    Conduct  Page 8




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
    Data transmitted
    and/or
    stored electronically by the Companies shall be protected from
    errors, disasters, misuse, unauthorized access, and fraud.  2.
    No
    employee may create or participate in the creation of any
    records that contain false information or that are intended to
    mislead anyone or conceal anything that is
    improper.    
    All assets and transactions must be recorded in normal books and
    records.
    No unrecorded funds shall be established or maintained for any
    purpose.
    All expense reports must accurately reflect the true nature of
    the expense.
    Oral and written descriptions of transactions, whether completed
    or contemplated, provided to those responsible for the
    preparation or verification of financial records must be
    accurate.    D.
    Policy
    Regarding Governmental Investigations        
    destroy or alter any documents in anticipation of a request for
    those documents from any government agency or a court,
    lie or make any misleading statements to any government
    investigator, or
    attempt to cause any other company employee, or any other
    person, to fail to provide appropriately requested information
    to a government investigator or to provide any false or
    misleading information.    Code of Business
    Conduct  Page 9




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E.
    Compliance
    with Laws  1.
    Know,
    respect and comply with all laws, rules and regulations
    applicable to the conduct of our businesses    
    make the effort to understand the laws and company policies that
    apply to your specific job responsibilities,
    review educational materials provided to you and participate in
    all required training programs, and
    ask questions of and seek advice from our Legal Department and
    be guided by the advice received.    2.  Privacy Laws.
  
    Our HIPAA Privacy Policies govern how we use and disclose
    certain kinds of health information that is protected under the
    Health Insurance Portability and Accountability Act of 1996
    (HIPAA) and its implementing Privacy Rule regulations.
    In addition, we may be subject to additional contractual
    obligations with respect to maintaining the confidentiality of
    such information.
    Finally, we have Privacy Policies posted on our Web sites that
    set forth standards regarding our use of information collected
    through those sites.    3.  Antitrust Laws.
    
    to set or control prices,
    to allocate customers or territories,
    on bidding terms or whether or not to submit a bid for
    particular business or types of business, and
    to boycott customers or suppliers.    Code of Business
    Conduct  Page 10




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4.  Anti-Kickback Laws. Anti-Kickback
  5.  Other Healthcare
    Laws.
  
    reducing fraud and abuse in federal healthcare programs
    (Medicare and Medicaid),
    eliminating the improper influence of financial incentives on
    medical judgment,
    protecting patients and improving the quality of healthcare
    services, and
    reducing the cost of healthcare.    F.
    Protection
    of Proprietary Information        need-to-know;
      Code of Business
    Conduct  Page 11




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G.
    Corporate
    Political Activity      his/her
              Code of Business
    Conduct  Page 12




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H.
    Relations
    with Governmental Bodies and Agencies and their Officials (and
    Former Officials)      any
      I.
    Economic
    Sanctions and Trade Embargoes       Code of Business
    Conduct  Page 13




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III. COMPLIANCE
    AND ENFORCEMENT
  A.
    Certification    B.
    Reporting
    Violations of this Code of Conduct  1.
    Reporting
    known or suspected violations of this Code of Conduct or any
    legal or ethical obligations is the responsibility of every
    employee  Do not assume that senior management already
    knows or that someone else will make the report.
  and/or
  2.
    You
    may make reports anonymously if you choose to do
    so  and/or
  3.
    Non-Retaliation
    Policy    Code of Business
    Conduct  Page 14




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NON-RETALIATION POLICY
  We are committed to providing a workplace conducive to open
    discussion of our business practices. It is our policy to
    protect employees who make reports, in good faith, of potential
    violations of our Code of Business Conduct, the policies in our
    Employee Handbook, other company policies or applicable law. In
    addition, it is our policy to comply with all applicable laws
    that protect employees against unlawful discrimination or
    retaliation by their employer as a result of their lawfully
    reporting information regarding corporate fraud or other
    violations of law by any of the Companies or their employees.
  Any employee who retaliates against another employee for
    reporting problems will be subject to disciplinary action, which
    may include termination of employment. If an employee
    believes that he or she has been subjected to any action that
    violates this Non-Retaliation Policy, he or she should report
    that to the Compliance Officer, to the appropriate General
    Counsel, to the Chief Financial Officer or to the Human
    Resources Department. This Non-Retaliation Policy applies even
    if an allegation that was made in good faith ultimately turns
    out to be groundless. However, employees who file reports or
    provide evidence that they know to be false or without a good
    faith belief in the truth of such information will not be
    protected by this Non-Retaliation Policy and may be subject to
    disciplinary action, including termination of their
    employment.
   C.
    Compliance
    Officer  858-759-6008. lleicher@webmd.net 92067-6306.
  D.
    Amendments,
    Waivers and Interpretations    and/or
      Code of Business
    Conduct  Page 15




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E.
    Investigation
    of Suspected Violations    F.
    Disciplinary
    Actions      
    the nature of the violation and the ramifications of the
    violation to the Companies,
    whether the individual was directly or indirectly involved in
    the violation,
    whether the violation was willful or unintentional,
    whether the violation represented an isolated occurrence or a
    pattern of conduct,
    whether the individual in question reported the violation,
    whether the individual withheld relevant or material information
    concerning the violation,
    the degree to which the individual cooperated with the
    investigation,
    if the violation consisted of the failure to supervise another
    individual who violated this Code of Conduct, the extent to
    which the circumstances reflect inadequate supervision or lack
    of due diligence,
    if the violation consisted of retaliation against another
    individual for reporting a violation or cooperating with an
    investigation, the nature of such retaliation, and
    the individuals past violations, if any.  Code of Business
    Conduct  Page 16