NOTE: Following publication of the blog below, 121Doc/HealthAffiliatesNetwork agreed to remove the US as a destination shipping option for all of its websites. They also removed text from the 121Doc.com website indicating (incorrectly) that the drugs are FDA-approved. LegitScript has accordingly modified the legitimacy classification to “unapproved” as opposed to “rogue” pending our continuing review into the legitimacy of the affiliate network’s operations in the EU.
LegitScript has re-designated all Internet pharmacy affiliates of 121doc.co.uk and 121doc.com, now known as the Health Affiliates Network, as rogue Internet pharmacies (about 100 in total).
As with most websites that we designate as rogue Internet pharmacies, there are three primary problems that we’re observing with HealthAffiliatesNetwork / 121Doc:
- The sale of prescription drugs without a valid prescription.
- The sale of unapproved drugs.
- The dispensing of pharmaceutical products without the required pharmacy licenses.
Here, a bit of history and context is helpful. The network says that it uses licensed physicians and pharmacies in the UK or elsewhere in the European Union to prescribe and dispense prescription medications, and allows Internet users to simply fill out an online form instead of actually being examined by the prescribing physician in person. The affiliate network, as we understand it, argues that it uses licensed physicians and pharmacies, and that it isn’t necessarily illegal in the UK for non-controlled prescription medications to be dispensed on the basis of an online consultation without a physical exam.
However, 121Doc, to date, has not disclosed to LegitScript the identities and locations of the physicians and pharmacies that they say they use to dispense prescription drugs. We invite them to do so, especially in light of the information (discussed below) indicating that the affiliate network is run, at least partly, out of Mauritius (a tiny island off the East Coast of Africa) – not entirely out of the United Kingdom.
Additionally, LegitScript has determined that the network’s affiliates are not in compliance with pharmacy practice requirements in some locations where they offer to dispense prescription drugs. Nearly two years ago, 121Doc complained about our rogue designation of their Internet pharmacies. We pointed out that in the United States, it’s a criminal violation of the Food, Drug and Cosmetic Act for a physician not appropriately licensed in the required US jurisdictions to write a prescription for a US patient and dispense those drugs to the US-based patient based solely on an online consultation. At the time (and still, as far as we know), 121Doc did not have a US pharmacy license but were nevertheless offering to ship drugs to the US.
LegitScript insisted that the network remove the US as a shipping option if they wanted us to consider modifying the rogue designation, in order to avoid violating the federal Food, Drug and Cosmetic Act (FDCA). They agreed to do so, and LegitScript modified their Internet pharmacies to “unapproved” designation. (LegitScript only notifies Registrars and ISPs about Internet pharmacies classified as “rogue.”)
Unfortunately, HealthAffiliatesNetwork / 121Doc has resumed offering to ship unapproved prescription drugs to the United States without a valid prescription or pharmacy license. Accordingly, we have reinstated the rogue designation for all affiliates of Health Affiliates Network / 121Doc until further notice, noting further that there is currently insufficient evidence for LegitScript to verify the source and supply of the drugs. However, we invite HealthAffiliatesNetwork / 121Doc to submit sufficient information to LegitScript that would result in a removal of the rogue designation.
HealthAffiliatesNetwork purports to be in the United Kingdom. Is it? Well, maybe; but flagship Internet pharmacy affiliate 121doc.com has the following domain name registration information:
Company: Top Care Ltd
Name: Santbakshsing N D
Address: Suite B1,2nd Floor, Wing B, Cybertower 1, Ebene Cybercity
Postal Code: 00000 / email: [email protected]
It is reasonable to inquire why a group working with licensed pharmacies in the UK and elsewhere in Europe need to center its operations in Mauritius. Indeed, the website for the email address used to register 121doc.com, topcare-services.com, indicates a location in Mauritius on the website it redirects to (topcareltd.com) but is registered to Peter Shove at 121Doc, albeit at a UK address – 2nd Floor, 145-157 St John Street, in London.
It is important to note that there’s probably not anything per se illegal about a pharmacy having an office in another country, but because HealthAffiliatesNetwork claims to only use licensed pharmacies and physicians in the UK, yet has not disclosed to LegitScript (and does not list on the website) those pharmacies’ and physicians’ identities, we think it leads to reasonable questions, both as to the corporate headquarters and the identities and location of the pharmacies and physicians that the network says it uses.
What about the UK address (2nd Floor, 145-157 St. John Street in London) that the network indicates its UK headquarters is at? Unfortunately, that just leads to bigger questions. LegitScript has written and tweeted extensively about Russian criminal pill gang Rx-Partners (formerly known as Stimul-Cash), which has thousands of rogue Internet pharmacy affiliates selling unregulated drugs without requiring a prescription from India and other locations.
The “anchor site” – the central website that provides most of the affiliate services, including order and payment processing – for Rx-Partners is rx-partners.biz. It so happens that the domain name registration information for that website lists the same address as that utilized by 121Doc:
Domain Name: RX-PARTNERS.BIZ
Sponsoring Registrar: ASCIO TECHNOLOGIES INC.
Registrant Name: Jessica Eagloff
Registrant Address1: 145-157 St John Street
Registrant City: 2nd Floor
Registrant State/Province: London
Registrant Postal Code: EC1V 4PY
Registrant Country: UNITED KINGDOM
Registrant Country Code: GB
Registrant Phone Number: +44.7005968172
Registrant Facsimile Number: +44.7005968172
Registrant Email: [email protected]
It is important to note that WhoIs registration can be falsified, and it may simply be a common use of the same corporation formation information, so this common address, by itself, is not dispositive information in establishing a link between 121Doc / HealthAffiliatesNetwork and Rx-Partners. However, the fact is that the address is linked to both Rx-Partners and 121Doc / HealthAffiliatesNetwork. If it is merely a corporate registration address for HealthAffiliatesNetwork / 121Doc, patients deserve to know where the actual dispensing pharmacy, not just a corporate agent, is located.
HealthAffiliatesNetwork / 121Doc can remove its rogue designation with LegitScript at any time by taking the following simple steps:
- Disclosing the identities, locations and licenses of the physicians and pharmacies the network uses to prescribe dispense prescription drugs.
- Discontinuing any violation of relevant laws and regulations by removing as a possible shipping destination, on the ordering pages, all locations where those physicians and pharmacies are not licensed (if they are required to be licensed there), and where the online consultation model that they use is prohibited.
We invite HealthAffiliatesNetwork to have its affiliate websites’ rogue designation removed by disclosing to us how the network is in compliance with the various laws where its websites offer to ship drugs to; and if not in compliance, removing those locations as shipping destinations.