Rogue Internet Pharmacies: An Update..PHARMACY: A Safe Domain For Patients. A Presentation for NABP

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1 Rogue Internet Pharmacies: An Update.PHARMACY: A Safe Domain For Patients A Presentation for NABP

2 About LegitScript Headquartered in Portland, Oregon / Staff of ~30 people / Founded 2007 Monitors websites facilitating the sale of prescription and OTC medicines, dietary supplements, designer drugs, and other regulated healthcare products. Global focus Classifies Internet pharmacies (etc.) by legal compliance with target market laws, associated criminal network if applicable. Recognized by NABP. Since 2008, shut down over 35,000 websites engaged in illegal sale of prescription drugs online Sample Clients: Google, Microsoft, Amazon, Twitter, other public and private entities, assists with Operation Pangea

3 Goals of This Presentation Internet Pharmacy Enforcement Update: How are things going on the Internet? Using Internet Governance to Fight Rogue Internet Pharmacies: The rules that govern the Internet.PHARMACY: That s dot pharmacy a new, safe corner of the Internet for patients

4 Part I Internet Pharmacy Enforcement Update

5 Can Internet Users Tell the Difference?

6 Can Internet Users Tell the Difference?

7 Can Internet Users Tell the Difference?

8 Internet Pharmacy Market Quick Facts 97% of websites selling prescription drugs online fail to comply with applicable laws/regulations. No valid prescription required Unapproved/unregulated drugs Lack of valid pharmacy licenses Top target markets: US, EU, Japan. But global problem. ~95% of Internet pharmacy websites are part of an affiliate network. But, only about networks, representing ~40,000 online pharmacies.

9 What is an Affiliate Network?

10 What Does it Take to Operate Your Own Online Pharmacy? Open your own online pharmacy in seconds No need for medical or pharmacy training Organized criminal network handles drug shipments You run the website for a commission of each sale

11 RxProfits: The name says it all

12 Typical Structure of Network RxProfits.com Open your own online pharmacy! Download template All you need is a domain name and server! Multiple bank accounts $$$ Payment 5% 60% commission Insert picture of website Drug suppliers Use of multiple suppliers Over 1,000 online pharmacies!

13 How do the Rogues Get Bank Accounts? The Online Pharmacy Accepting Payment with Credit Cards

14 Give me a credit card account I m just selling supplements! The Dietary Supplement Website Used to Get the Account

15 Part II Long Term Strategy: Disrupting the Rogue Internet Pharmacy Market using the rules of the Internet

16 Fighting Back: Make Life Impossible for Rogue Internet pharmacies What rogue Internet pharmacies need to survive Search Engine Advertising (Google, Bing, Yahoo) A Way to Get Paid (VISA, MasterCard, etc.) Domain Names (GoDaddy, Nominet, etc.) A way to Ship the Drugs (UPS, FedEx, DHL, etc.)

17 How is it going? The current status Search Engine Advertising (Google, Bing, Yahoo) Very clean. Ads only. Chokepoints: Three to five. A Way to Get Paid (VISA, MasterCard, etc.) Improvement in progress. Chokepoints: Four five big ones. Domain Names (GoDaddy, Nominet, etc.) Partly clean/partly dirty. Chokepoints: ~500. A way to Ship the Drugs (UPS, FedEx, DHL, etc.) Partial improvement in progress. Chokepoints: Four to six+.

18 To Understand the Rules of the Internet, we Have to Understand What a Website Is Domain Name: buylosartan.com Requirements and Dependencies Name Servers: Ns1.securerxorder.com Ns2.securerxorder.com A website is actually a domain name that points to content on an IP address. The name servers are what point the domain name to the content. IP addresses: Shutting down a website? It s all about the name servers.

19 The Rules of the Internet All registrars bound by Uniform Dispute Resolution Policy (domain name must not be...registered for an unlawful purpose or...knowingly use(d) in violation of applicable laws or regulations. ) Many registrars have resellers; however, these are not directly bound by ICANN policies and procedures. ICANN UDRP RAA GoDaddy enom Key Systems reseller contract reseller contract UDRP via AUPs UDRP via AUPs NameCheap UDRP via AUPs reseller UDRP via AUPs Registrant Registrant Registrant Registrant Registrant Registrant

20 Examples of rogue Internet pharmacy shutdowns Example of a rogue Internet pharmacy shutdown: fillmyscript.com

21 Correspondence With Rogue Internet Pharmacy Operator

22 NABP Leadership Against the Nanny Nanny Billy Goat Strategy Rogue Internet Pharmacy Argument Websites only have to adhere to applicable laws I m not in the US, neither are my servers, the drug supplier or the domain name. I don t ship to the countries where I am, or my servers, the drug supply or my domain name are. Therefore, there IS NO APPLICABLE LAW I can do what I want! Buhahaha. NABP Letter to ICANN (Oversees Registrars) Registrars (must) adhere to applicable laws the sale of medicines must adhere to the laws and the regulations both where the merchant operates from, and in any jurisdiction where the merchant offers to dispense or ship the medicines to.

23 Clustering at Friendly Registrars 17% 18% Rogue % TodayNIC (CN) BizCN (CN) 4% 4% 5% 15% Joker (CZ) Tucows (CA) WebNic (MY) Rebel (CA) 7% 8% 10% 12% Key Systems (DE) Cloud (US) DattaTEC (AR) Others This means that 83% of rogue Internet pharmacies are clustered at just 10 registrars out of ~500.

24 Financial Systems Strategy A Way to Get Paid (VISA, MasterCard, etc.) Rule: Merchants must comply with laws at drugs POINT OF ORIGIN and SHIPPING DESTINATION. Criminals strategy: Set up merchant account selling books or shoes Claim that they are legal banks don t know Geotargeting: What you see depends on where you are

25 LegitScript Long Term Strategy Cluster rogue online pharmacies at a few registrars, then go after those registrars Help credit card companies identify banks that are most often used as safe havens Continuing public education, showing that a website claiming to be a legitimate online pharmacy may be rogue

26 Recommendations for Boards of Pharmacy What intermediaries are in your state? Talk to them. Registrars Registries Banks Social media ISPs School of pharmacy courses should include education re: Internet laws/ethics Rogue Internet pharmacies are a type of cybercrime. Boards of pharmacy should consider basic training.

27 What About Rogue Internet Pharmacy Operators in Your State? fillmyscript.com controlled by individual in Indiana. Profiting from sale of controlled substances, other Rx drugs w/out a prescription or valid pharmacy license (but not handling/dispensing drugs directly). No pharmacy training, not a pharmacist or pharmacy. Does Indiana BOP have jurisdiction? If not, should state laws/regulations be updated to address this?

28 Part III.Pharmacy: a Safe Place for Patients

29 About Dot Pharmacy A new top level domain name only for legitimate pharmaceutical websites (like.com,.net,.biz, etc.) Global in nature, not only for US. Operated by NABP Websites MUST adhere to laws where they operate from, and where they offer to ship to

30 Look to the Right of the Dot! CVS.pharmacy, drugstore.pharmacy, amber.pharmacy, etc. Easy way for Internet users to ensure legitimacy. If right of the dot is pharmacy, it is safe and legitimate. If not dot pharmacy, then less assurance of legitimacy.

31 Questions and Answers What are the standards to verify legitimacy? What if it is legitimate in another country but not licensed in US? What if the Internet pharmacy goes rogue? How will.pharmacy websites be monitored?

32 Free Services for Boards of Pharmacy Report a rogue to LegitScript. We can often get it shut down. Always happy to answer questions about affiliate network, de confliction, help pass on information to right agency. New: Problematic product monitoring program. Global classification and compliance program for dietary supplements, designer drugs Three categories: 1) neutral, 2) per se problematic ( tainted ), and 3) context dependent (marketed with false claims). Free account lets you find out if other countries drug safety agencies have taken action.

33 Thank you! This is a battle we can win! Questions?

John C. Horton President, LegitScript

John C. Horton President, LegitScript JOHN HORTON PRESIDENT January 17, 2013 European Commission, DG SANCO Unit SANCO/D/6 DM24 02/36 BE-1049 Brussels via email: sanco-logo-falsified@ec.europa.eu Dear Sir or Madam: LegitScript appreciates the

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