The LegitScript Blog

The Medicines and Healthcare products Regulatory Agency (MHRA) of Britain has announced the successful raid of several rogue online prescription drug peddlers. The raid, coordinated by INTERPOL, occurred last Wednesday and targeted web-based operations in nine countries that were selling prescription-only medications without the proper authority to do so. The sites offered medications for conditions ranging from diabetes, to male impotence, to obesity without requiring a valid prescription and without being licensed. Besides the fact that such transactions are potentially very harmful depending on the integrity of the drugs and a patient’s medical history, the raid also has larger implications. In carrying out this raid, the MHRA and other involved organizations have shown that the International community will not tolerate rogue Internet pharmacies.

The MHRA stated that they have contacted the appropriate Internet Service Providers (ISPs) to have these sites taken down. LegitScript is hopeful that these ISPs will follow the lead of others, like Directi, which have responded to LegitScript’s alerts of similar sites by swiftly taking them down.

LegitScript strongly supports an international approach in combating the ever-growing problem of these, essentially, online drug dealers. To get an idea of the scope of the problem, read on:

“In many countries, the abuse and trafficking of prescription drugs now equals or exceeds the use of illicitly manufactured heroin, cocaine, amphetamine and opioids”, according to the Vienna-based International Narcotics Control Board.

LegitScript applauds the efforts of the MHRA to keep illegal prescription drugs off the online market.

Right after we took down those 500 websites we just blogged about, we added another into the mix: WestCoastDrugs.com, which was advertising through Shopping.com.

Here’s the interesting thing about WestCoastDrugs.com: if you went to their homepage, you only found non-controlled substance prescription drugs. But through Shopping.com, they were advertising controlled substances like Meridia, a weight-loss drug and Schedule IV controlled substance.

We’re pleased to announce the largest Internet pharmacy website shutdown in our history: nearly 500 rogue Internet prescription drug or steroid websites, terminated. These include websites like:

• Steroids-Pharmacy.com and Advanced-Stealth.com, which sold anabolic steroids, Schedule III Controlled Substances, without requiring a prescription, from overseas.
• Diettabs.net and MedicationsStock.com, part of the Meds-Easy network, which offers some real and some counterfeit prescription drugs from overseas without requiring a prescription, including controlled substances.
• DrugsBroker.com, part of the Stimul-Cash network, and DrugstoreOne.com, part of the PharmaMedics network, both of which offered prescription drugs without requiring a valid prescription, usually from overseas.

We’re making progress on an international scope in getting domain name registrars to shut these websites down.

And who’s behind these websites? Let’s take a look at just five previously anonymous WhoIs registrations that have now been exposed.

Steroids-Pharmacy.com

Samuel Aboda Keaparti

Igelopi Kan Ltd.

advanced-stealth@hushmail.com

86/12 Ratchadapisek Road Room 204, Ladyau,

Bangkok, TH 10900

Tel No. +66.22465833

Advanced-Stealth.com

Samuel Aboda Keaparti

Igelopi Kan Ltd.

advanced-stealth@hushmail.com

86/12 Ratchadapisek Road Room 204, Ladyau,

Bangkok, TH 10900

Tel No. +66.22465833

200drugs.com

Alex Chepurnoy

alexch@bk.ru

Severniy avenue 10/1 flat 101

Saint-Petersburg, Russia 194354

Tel No. +7.8122962603

PillSeller.com

Dmitry Balandin

dm-balandin@yandex.ru

Moskva, RU 107143

Tel No. +7.9030000000

In the middle of verifying the legitimate Internet pharmacies and exposing the illicit ones, we like to take some time now and then to chuckle about some pretty funny domain names for Internet pharmacies. So here’s the beginning of a tradition: Every year, we’ll release our Top Five Funniest Rogue Internet Pharmacies.

Here’s the top five, in reverse order, for 2008.

5. Givebuckyachance.com. Who is Bucky, and why should we give him a chance? Really folks, this is no name for a pharmacy. Poor Bucky. Bucky’s life is apparently so tough that he needs to join the “Indian Drugs” rogue Internet pharmacy network to get ahead. We’d like to give Bucky a chance, but we’ll pass on this website, which offers to dispense prescription drugs in violation of several laws, and without requiring a prescription. The website is actually registered to Uli Brau in Afghanistan.

4. BandjDrugPusher.com. Well. The name just doesn’t pull punches, does it? This website is an affiliate of rogue network XL Pharmacy, which also offers prescription drugs from India without requiring a valid prescription. Does that sound like drug pushing? It sure does to us. Still, we’d sure like to know who “B and J” are. (Could “B” be Bill Todd, the website’s registrant? Stay tuned.) Drugs-Dealer.com, an affiliate of Affiliate Pharmacy Network, is another good one.

3. BlackMarketMeds.com. Now, if there’s an Internet pharmacy whose name inspires legitimacy, this one is it:

“Hello, Black Market Meds, may I help you?”

“Yes, do you have Tramadol?”

“Yes, but only the fake stuff. We don’t carry any real drugs. Are you paying with insurance, or out of pocket?”

The website is an affiliate of rogue network RxPayouts.com which doesn’t require a prescription prior to dispensing prescription drugs. Underground-pharmacy.com is a good one along these lines.

2. DoctorDuck.com. The website’s been terminated (it was an affiliate of “Canadian Pharmacy”) but when it was up, we had the odd feeling that the physician writing prescriptions for this website may have been something of a quack. (Groan.)

1. WallofFear.com Again, this one has been terminated (also a “Canadian Pharmacy” affiliate). Apparently, this pharmacy’s customers are cowered outside the pharmacy, trembling with fright: are the prescription drugs really FDA-approved? (Answer: No, they are counterfeit, in fact.) But really…why would anybody in their right mind purchase prescription drugs from an Internet pharmacy called “Wall of Fear”? (We can see it being used as the name for an online dating site, but that’s a different story.)

Honorable Mention: Finally, for the sheer image it conveys, we give the Honorable Mention to WorkingGranniesMeds4Less.com Enough said.

The Industry Standard reports that a former Internet pharmacy affiliate marketer named Mike Geiger was a featured speaker at the WebbyConnect conference a few weeks ago. The Standard says that Gieger:

used to have what sounded like a thriving side business setting up sites that sent affiliate traffic to illicit pharmaceutical sites.

The Standard reports that Gieger, in his presentation,

...was unrepentant about his role in the trade. Affiliate marketing is a “completely legit business,” he said, and went on to describe himself as a mere middleman uninvolved with the actual distribution of the drugs. “Why did I choose pharmaceuticals? It was very simple,” he said. “[It was] because I would get up to 45% of whatever I sold.”

Here’s a simple question. First, let’s assume that the website Gieger operated was selling controlled substances like Xanax, Phentermine, or Ambien without a valid prescription, or any prescription at all. (Although frankly, the same point can be made if the drugs are any prescription drugs, even non-controlled ones.)

What’s the difference between what Gieger was doing and a person who stands on a street corner and says, “Hey kid…come with me and I’ll take you to the crack house down the street where you can get some really good stuff,” and then pockets 45% of the crack cocaine sale without ever touching the drugs?

The answer is, there’s no difference. The guy on the street corner can also claim that he’s not the one actually distributing the drugs. But does that absolve him of responsibility for the illicit distribution? Of course not: he’s the point man, the lookout for customers, the facilitator of the transaction. He’s the one that enables the actual distributor to make the sale and hide behind a shield of anonymity.

The same concept is at work for affiliates of rogue Internet pharmacy networks. The affiliate marketer who sets up a website selling these drugs may not handle or dispense the actual drugs. But he’s part of the drug dealing scheme or conspiracy: he recruits the customers and shares responsibility for the sale.

Gieger’s protestation that he lacks any responsibility for the transaction should not go unchallenged. And it’s an important wake-up call for those in the policy arena who want to see a reduction in the number of websites illicitly offering controlled substance prescription drugs.

The International Commission for Assigned Names and Numbers (ICANN) has terminated rogue Internet pharmacy sponsor ESTDomains.

That’s great news, and it’s big. EST Domains is a huge sponsor of rogue Internet pharmacies. Of the domain name registrars that we track, it’s probably number two or number three, depending on how you calculate it.

But let’s back up. For those who don’t follow this issue, a domain name registrar is an entity authorized by ICANN to sell domain names. For example, when we decided to use the name LegitScript.com, we went to Network Solutions and registered that domain name. Any DNR like Network Solutions, GoDaddy or eNom can only sell domain names as long as ICANN continues to give them permission to do so.

ESTDomains’ problems began with the fact that Vladimir Tsastsin, the President of the Company, was convicted of several crimes, including forgery and credit card fraud. This is contrary to ICANN rules, and is grounds for termination. But the real impetus for the termination was the fact that an overwhelming number of rogue websites (Internet pharmacies and others) looked to EST Domains as a safe place where, regardless of what sort of illegal activity they engaged in, they wouldn’t be terminated. For several months, a loose coalition of online safety organizations like KnujOn and CastleCops pressured ICANN to adhere to its own standards, which allow termination for this sort of illegal activity.

But here’s the question: what happens to the 281,000 domain names currently registered with ESTDomains? ICANN policy requires that they be transferred to another DNR within the next several weeks. On the one hand, some websites are legitimate and we hope that their operations aren’t affected. But plenty are rogue sites engaged in illegal activities involving malware, counterfeit pharmaceuticals, and other illegal activity.

This is the perfect opportunity to get those websites terminated. Will it happen? Stay tuned.

UPDATE: ESTDomains has alleged that Tsastsin had already resigned and is appealing the decision. ICANN has agreed to stay the termination pending their review of ESTDomains’ request.

Mesomorphosis.com, a steroid law reform website, emailed us with some questions about our request to GoDaddy and other US-based registrars to terminate some steroids websites. (See Mesomorphosis’ blog on the same topic.) Most, but not all, of the websites were terminated.

Mesomorphosis asked some great questions, and we’re happy to answer them below. (NOTE: We abbreviated a couple of the questions for the sake of brevity.) Feel free to download the original steroids report as background.

1. LegitScript has asserted that it is irrelevant that some steroid pharmacies are operating legally within their respective countries. Is it fair to identify a steroid pharmacy website as illegal or “rogue” in the absence of proof that they are violating any laws? After all, products on a website are marketed to a worldwide audience (including residents of the United States) due to the very nature of the Internet.

Yes, it’s fair. These websites all allow the sale of these products to the US from outside of the US, which violates numerous US laws and is unsafe. In many cases, the “default” setting for a country selection is the United States (or, the United States is the top selection) and the FAQs talk about what to do if US Customs intercepts the package. It’s naive to pretend that the US isn’t the intended audience in these cases.

We have rarely, but occasionally, found prescription drug websites that do not allow the product to be ordered if the shipping address is in the United States. We leave those websites off of our lists. All that a steroids website has to do is remove the ability for a recipient in the US to order steroids without a prescription, and we’ll leave the site alone.

2. LegitScript has asserted that U.S. law should have precedence in determining the legality of a steroid pharmacy (at least when it comes to U.S.-based registrars). Does LegitScript feel that other countries should conform to the legal standards set forth by the United States with regard to steroid and prescription laws?

Our position is not that US law should have precedence above other countries’ laws in determining the legality of a steroid website. Rather, a website that ships prescription drugs from one country into another needs to comply with both countries’ laws. In other words, if a steroid website is shipping steroids to the US, those shipments must adhere to US law.

3. Some of the websites LegitScript submitted for termination do not appear to sell anabolic-androgenic steroids (AAS), but rather discuss the non-medical use of AAS, provide information generally, are affiliates of websites selling prescription drugs, or advocate their decriminalization or legalization (e.g., isteroids.com). Does LegitScript request termination of those websites?

No. We don’t have any problem with websites advocating a change in the law, or that are really doing nothing but providing information about anabolic steroids. However, that’s not what isteroids.com was (or, now that it’s re-registered elsewhere, is) doing. The website consistently displays an ad for, and link to, steroids-pharmacy.com, which provides anabolic steroids without requiring a prescription. The fact that the purchase is actually made from steroids-pharmacy.com, not isteroids.com, is irrelevant: iSteroids.com is functionally a storefront or entry point for steroids-pharmacy.com.

In the online prescription drug/steroids world, it’s a common scheme to set up a website that initially seems to be informational, but in some prominent way, obviously and overtly encourages its users to visit another site or sites for the illicit purchase of prescription drugs or steroids. In these cases, it’s not accurate to describe the website as simply informational. Rather, it’s an important part of the illicit network. Besides, each time that an Internet user on that informational page clicks through an advertisement to a steroids selling website, the informational page typically gets a fee or cut of the sale, and is directly or indirectly sharing in the drug proceeds.

4. Where can consumers access a revised list of “rogue” websites?

We actively maintain that list, but do not publish it. One reason is that we don’t want potential purchasers to use that list as a resource for finding sites where they can purchase drugs without a valid prescription. However, the “Is It Legit” box on our home page is a closed-universe search engine that lets users search for a website to see if it is approved or unapproved.

These days, the economy affects just about every aspect of our lives. The big decisions, like buying a new car or trying to get that small business loan, are being shelved while we wait for friendlier financial times. And increasingly, the smaller, everyday decisions are getting more scrutiny as our collective wallet tightens. One of these so-called small decisions? Filling prescriptions.

An article in today’s New York Times describes the situation in which many Americans now find themselves: “People are having to choose between gas, meals and medication,” said Dr. James King, the chairman of the American Academy of Family Physicians.

With the average number of prescriptions per person on the rise- jumping from 8.9 in 1997 to 12.6 in 2007- combined with climbing insurance co-pays, people are starting to pick and choose which prescriptions they fill in an effort to balance the household budget.

What does this have to do with the Internet pharmacy market?

Many rogue Internet pharmacies claim that their drugs are considerably cheaper than the ones you’d get at your local pharmacy. It’s an effective strategy. (Never mind the fact that these “drugs” might have been made in someone’s basement. And never mind, also, that legitimate generics are often much cheaper than the drugs pushed by these rogue sites.)

As American consumers look for creative ways to cut daily living expenses, the “Cheap meds!”, “85% discount!”, “Beat any price, guaranteed!” advertisements of the rogue Internet pharmacies may well gain appeal.

LegitScript’s take is that falling for these ads and purchasing prescription drugs from illicit sources sharply increases the risk of receiving counterfeit, expired or otherwise substandard medications. A recent study by the European Alliance for Access to Safe Medicines found that over 60% of drugs purchased in test-buys from Internet pharmacies were counterfeit or substandard. Interestingly, the study also found that to the untrained eye (read: average consumer), the drugs appeared legitimate.

The bottom line? The cost of such a risk far outweighs the benefit of a few (potentially imaginary) saved dollars.

Following on our recent blog about affiliate pharmacy networks, ZDNet had a blog from Ryan Naraine, Dancho Danchev & Adam O’Donnell about the structure of pharmaceutical affiliate networks.

One excerpt from the blog is revealing:

So once you’ve been approved as an affiliate and receive your unique tracking code, you’re free to choose the pharmaceutical products, pick up the creative and choose of the many templates for online pharmacy shops, then start driving traffic to them. (Emphasis added.) Some affiliate programs add value to the registration process by introducing ratio calculators in order to make it easier for new participants to calculate their earnings based on the selling price that they choose for the item.

The domain name registrant (the affiliate) is able to choose the pharmaceutical products sold on the website, is responsible for driving traffic to the website, and gets a cut of sales through the website. If the drugs are sold without a valid prescription or in violation of other laws, what sort of criminal liability does the registrant face? Law enforcement has traditionally targeted individuals higher up in the organization, not domain name registrants, unless he or she was also involved at the upper echelons of the criminal organization.

We think that affiliate registrants are about to face greater risk. Because the website registrant chooses the drugs sold on the website, and is responsible for the website’s search engine optimization and/or advertising, there’s an arguable case for criminal liability. After all, it’s indisputable that the affiliate network thrives, in part, because of the hordes of individual affiliates who boost search engine optimization, often anonymously.

With that, here’s a tidbit from LegitScript. In at least one state legislature (we’re not telling which one), legislation is going to be introduced early next year that will specifically hold the registrants of websites selling prescription drugs accountable. They’ll have to notify the Board of Pharmacy in their state if they are the registrant of any website offering prescription drugs. And the registration will have to be accurate, not anonymous.

A full solution? Of course not, especially with just one state. But this brings us back to the point we always raise about rogue Internet pharmacies and transparency: rogue pharmacy affiliate networks hate the sunlight. If this rule were enacted in all 50 states, it would be a good way to slow the proliferation of rogue affiliate websites.

Today, President Bush signed the Ryan Haight Online Consumer Protection Act.

LegitScript’s President co-authored an op-ed more than a year and a half ago calling for the Act to be passed. We’re glad to see it finally has become law. (But, as we’ve noted before, it only applies to domestic websites selling controlled substance prescription drugs, and therefore does not, in a practical sense, apply to the vast majority of Internet pharmacy websites.)

LegitScript will blog more about the new law over the next several days.