Report - LegitScript
Transcription
Report - LegitScript
Pumped up on the internet The Illicit Online Sale of Anabolic Steroids A special report by LegitScript.com and KnujOn.com Overview: Pumped Up On The Internet The national abuse of Steroid Use: Teens and Young Adults (1991 - 2006) prescription drugs, a 8th graders category that includes 5.00% 10th graders anabolic steroids, has 12th graders climbed to disturbing 3.75% Young Adults levels over the last fifteen years. According to the 2.50% National Survey on Drug Use and Health, 1.25% prescription drug abuse is now the second most 0% serious drug threat in the 1991 1993 1995 1997 1999 2001 2003 2005 country, behind only marijuana.1 Today, there are more prescription drug abusers than abusers of methamphetamine, cocaine and heroin combined. Within this troubling trend, studies indicate that illicit steroid use among high school seniors, a bellwether demographic, doubled from 1993 to 2002. Although it then began to decline, it has recently begun to tick upwards again, following the general upward trend observed in the early 1990s 2. The fact that steroid abuse in the United States is About LegitScript.com LegitScript was formed in May 2007 to assist consumers and businesses in determining which Internet pharmacy Web sites meet the requirements of law and accepted standards of medical practice, pharmacy practice, and ethics. LegitScript online pharmacy verification standards are recognized by the National Association of Boards of Pharmacy® (NABP®). LegitScript Internet pharmacy verification standards constitute the minimum criteria required for a pharmacy Web site to be considered “legitimate” in light of existing federal and state laws and regulations, accepted standards of medicine, accepted standards of pharmacy practice, and other drug safety requirements. About KnujOn.com KnujOn.com was formed in March, 2005 to find new and comprehensive solutions to the problems of spam email abuse and Internet criminality. Illicit traffic on the web has exploded to to a lack of oversight and enforcement. KnujOn developed a tool called the Policy Enforcement Engine (patent pending) that processes spam through the complex bureaucracy and terminates illicit websites. KnujOn has succeeded in removing nearly 100,000 spam advertised websites from the Internet. KnujOn works on behalf of the consumer, business and law enforcement to make Internet commerce safer. 1 US Department of Health and Human Services, National Survey on Drug Use and Health (NSDUH) 2006, September 2007. 2 Johnston, L. D., O'Malley, P. M., Bachman, J. G., & Schulenberg, J. E. (2008). Monitoring the Future national results on adolescent drug use: Overview of key findings, 2007 (NIH Publication No. 08-6418). Bethesda, MD: National Institute on Drug Abuse, 70 pp. 1 concentrated in the high school population (which is very Internet-savvy), and tapers off after high school3, suggests that our youth are particularly at risk, and makes the question of steroid abuse a timely and important one. What are anabolic steroids? Steroids may be legitimately prescribed for a few medical conditions such as hypogonadism, delayed puberty, and wasting caused by HIV. The word “anabolic” means “tissue building.” Although “roids” do increase muscle development, adverse effects include acne, male breast development, liver cancer, heart attacks, elevated cholesterol levels, stunted growth, and extreme irritability and aggression known as “roid rage.” Anabolic steroids are Schedule III Controlled Substances under US Federal law. Against this backdrop, the number of Internet pharmacies illegally offering and distributing steroids has exploded. According to the White House Drug Policy Office and the Drug Enforcement Administration, the Internet is one of the two primary sources of illicit anabolic steroids in the United States.4 To describe how much this problem has grown, in the year 2000, the Government Accounting Office estimated that there were 200 - 400 Internet pharmacy websites total ⎯ a number that included all legitimate and illegitimate sites selling any sort of prescription drug, not merely steroids.5 And in 2004, a national study identified 495 websites selling controlled substance drugs online, a category that includes anabolic steroids.6 Today, LegitScript and KnujOn estimate that at any one time, there are at least 25,000 websites7 that offer or purport to offer prescription drugs without a valid prescription; of these, certainly hundreds, and perhaps thousands, offer anabolic steroids without any sort of medical supervision or prescription required. 3 Ibid, p. 127. 4 Office of National Drug Control Policy (www.whitehousedrugpolicy.gov/drugfact/steroids/ steroids_ff.html), accessed July 13, 2008. The second source is smuggling from outside of the country. 5 United States Government Accounting Office, Internet Pharmacies: Adding Disclosure Requirements Would Aid Federal and State Oversight, October 2000. 6 National Center on Addiction and Substance Abuse at Columbia University, Youʼve Got Drugs! Prescription Drug Pushers on the Internet, February 2004. 7 Our estimate of 25,000 is not exact, but is based on LegitScriptʼs and KnujOnʼs analysis of the rogue Internet pharmacy market. Rogue Internet pharmacies commonly put up a site for just days or even hours, and then take the site down; in many of these cases, the site will pop up weeks or months later. Including these sites, LegitScript has already identified and documented approximately 8,000 rogue pharmacy websites; KnujOn has identified another 45,000 websites that are candidates for identification as rogue pharmacy sites by LegitScript. LegitScriptʼs analysis of these suggests that between 45 - 60% of the 45,000 sites are rogue pharmacy websites, suggesting that the total number of sites used to illicitly offer prescription drugs is probably in the 20,000 - 30,000 range at a minimum. 2 LegitScript and KnujOn have narrowed the focus of this report to more than 150 websites that offer or purport to offer anabolic steroids without a prescription, and that are registered to domain name registrars located in the United States. These 150 websites constitute just over half of a larger group of 300 websites that LegitScript and KnujOn believe to be responsible for a significant portion of illicit steroid sales over the Internet to residents of the United States. (The remaining websites differ only in being registered to domain name registrars located outside of the United States.) In other words, the 150 websites that are the primary subject of this report constitute, for reasons we explain later in this report, a significant portion of the online anabolic steroid problem, but a small portion ⎯ probably less than 1% ⎯ of the overall rogue Internet pharmacy problem. For that reason, we believe that the information in this report can accurately be considered the most comprehensive study, to date, of websites illicitly selling steroids, as well as an important snapshot of one dimension of the larger rogue Internet pharmacy problem. Domain Name Registrars and Illegal Websites Can anything be done about rogue steroid websites? Too often, the problems of drug abuse, rogue Internet pharmacies, and spam are met by weary resignation ⎯ the notion that nothing can be done. In fact, the situation is far from hopeless: domain name registrars ⎯ the companies that sell domain names (e.g., “www.steroids.com”) and enable the activation of websites on the Internet ⎯ have the ability to “take down”, or make inaccessible, any website they have registered. From a technical perspective, this usually involves preventing the ability of the domain name to “resolve” ⎯ or, in layman’s terms, preventing the website from appearing in a browser (e.g., Internet Explorer) when one types the domain name into that browser. In its place, the domain name registrar can put empty space, an error message, or redirect Internet traffic to the domain name registrar’s home page. In addition to having the technical ability to make rogue steroid websites inaccessible, the domain name registrars have the contractual obligation and/or contractual opportunity to do so. Each domain name registrar noted in this report requires customers to agree to a “User Agreement” or similar legal document. These agreements prohibit the use of a website for illegal purposes, and give the domain name registrar the right to make the website inaccessible if that provision is violated. Further, the International Commission on Assigned Names and Numbers (ICANN), the international organization responsible for oversight of domain name registrars, has long maintained a policy position requiring domain name registrars to prohibit illegal activity on their websites in these User Agreements. 3 Of course, in addition to having the contractual obligation to take down websites engaged in drug dealing, most Americans would likely agree that the domain name registrars have a social or moral obligation to do so. LegitScript and KnujOn decided to test whether the domain name registrars were living up to those obligations. We therefore took the following steps. ➡ First, as noted above, we identified approximately 300 websites that LegitScript and KnujOn believe to be responsible for illicit anabolic steroid sales in the United States. Our joint list is not a comprehensive list of all illicit anabolic steroid sites, but does constitute, we believe, a “significant chunk” of the online anabolic steroid threat. Anabolics4fitness.com, which offers, on the left, “Trenbol 100”, a product labeled as including trenbolone acetate, a Schedule III anabolic steroid. The site is registered to Dynadot, a domain name registrar based in the United States. LegitScript successfully submitted a request for another anabolic steroid without a prescription to thie site. . 4 ➡ Second, within those 300 websites, KnujOn determined that approximately 156 websites are using eight registrars located in the United States. We note that there is no requirement that USbased registrars only sell domain names to US residents. In fact, in all cases, the steroid websites registered with US-based registrars are physically located outside of the United States.8 ➡ Third, KnujOn and LegitScript sent letters to these eight domain registrars located in the United States. These letters contained the following information: 1. a list of the domain names of websites offering or purporting to be offering anabolic steroids without a valid prescription; 2. the Federal statute that makes possession of Schedule III drugs without a valid prescription a felony offense; Duraplex100, an anabolic steroid sold by www.duraplex100.com, which is registered to GoDaddy. LegitScript was able to complete an order for the anabolic steroid without a prescription. The website is part of the AxioLabsGear.com network, which is also registered to GoDaddy.com. (Source: www.duraplex100.com, www.godaddy.com.) 3. a list of anabolic steroids designated as Schedule III controlled substances by the Drug Enforcement Administration; and 4. a recitation of the section of the User Agreement (or equivalent document) prohibiting website use for illegal activity. At the conclusion of our letter, we requested that services to these websites be suspended, per the terms of the various User Agreements. Results of KnujOn’s and LegitScript’s requests to domain name registrars To date, the results of our correspondence with the domain name registrars have not been encouraging. To reach the registrars, we contacted them via the email address(es) 8 The fact that these websites are all located outside of the United States is, we think, a testament to the success of the DEAʼs efforts to identify, arrest and submit for prosecution individuals engaged in the illicit distribution of anabolic steroids within the United States ⎯ outside of which, of course, the DEA has limited or no jurisdiction. 5 listed on their website approximately three weeks prior to the issuance of this report, and sent an identical letter via the US Postal Service. The results of our correspondence is available in detail on our websites, at www.knujon.com/steroid_report_jul08.html and at www.legitscript.com/ steroidreport.html. KnujOn’s also includes .pdf files of the websites around the time that we reviewed them, as we expect that some of the sites’ content will change following the release of this report. Our findings are also summarized in an Appendix to this report. Our summary of correspondence is as follows: 5. Abacus America (one website). No response. Website remains active. 6. DSTR Acquisition VII (two websites). No response. Websites remain active. 7. Dynadot (one website). The company declined to take down the website unless contacted by law enforcement. Website remains active. 8. eNom (eight websites). The company emailed in response, indicating that it would decline to take action against these websites and is unable to do so. Websites remain active. Photograph of anabolic steroids for sale emailed to LegitScript by www.multihgroup.com, a website registered to Abacus America, Inc. (email from multihgroup@yahoo.com to private email, date intentionally undisclosed). The email requested that payment be sent to an individual in Ankara, Turkey. 9. EST Domains (four websites). No response. However, three of the four websites are now inaccessible; one remains active. It is unclear whether the sites were suspended by EST Domains or were removed by the website operator for other reasons. If EST Domains terminated the websites, we think that they deserve recognition for this; however, we are concerned that one of the four sites remains active. The three sites that are no longer accessible shared the same IP address. 10. Everyone’s Internet (one website). No response. Website remains active. 6 11. GoDaddy (155 websites).9 GoDaddy indicated that the matter had been referred to their abuse department; however, the websites remain active. (GoDaddy includes several subsidiaries or affiliates of the company, including WildWestDomains and DomainsByProxy.) 12. Parava (three websites). No response. Additionally, we are troubled to note that the physical address we sent the letter to appeared to be an invalid address, and the letter was returned. This letter was sent to the address provided on Parava’s website. The websites remain active. In short, most of the domain name registrars have, to date, declined to take action, despite their ability to do so, and their contractual and social obligations to do so. Here, we want to preemptively address a possible objection: that the domain name registrars do not know for sure that the websites are illicit, because LegitScript and KnujOn did not actually purchase from these websites and verify, through chemical testing, that the substances are anabolic steroids. We reject that explanation: for the most part, the sites in question have photographs of vials labeled with names of anabolic steroids; call the products an anabolic steroid; sell the injection equipment; accept payment; and in several cases, sent us emails, in response to our queries, instructing us how to make payment and receive shipment clandestinely to avoid detection by US Customs. If the sites are not engaged in the sale of actual anabolic steroids, there are only two alternative explanations: one, that the substances are counterfeit or adulterated, which is equally dangerous; and two, that the site simply takes the money and declines to send an order, which is fraudulent and considered theft.10 Any reasonable analysis of these websites leads to a conclusion that they violate the domain name registrars’ User Agreements.11 Here, a brief note about GoDaddy is appropriate. As with many sorts of businesses, domain name registrars range from the very small to the very large: some may register millions of websites a year, while others may merely register hundreds. For this reason, the fact that GoDaddy, has 155 websites on our list ⎯ more than 7 times all of the rest combined ⎯ should not be viewed in isolation, but partly as a natural consequence of that company’s position as the market leader in the United States for domain names. 9 10 Moreover, in the vast majority of cases, it is quickly and readily apparent that the site is offering or purporting to offer anabolic steroids. There are a handful of sites we reported that we recongize do require some further investigation: e.g., some sites appeared to be a password-protected administrative site controlling an illicit steroids site; another sells athletic supplements (presumably lawfully) but also sells an “anabolic steroid cleanser” that facilitates anabolic steroid use by enabling one to pass a drug test; and other sites may have been temporarily offline at the time we submitted them. Nevertheless, for the vast majority of websites we submitted, we think that there can be no reasonable question as to what is really going on with the website. 11 LegitScript and KnujOn note the existence of numerous websites that offer supplements with names similar to anabolic steroids, but that, upon a close reading of the product labels, are not in fact anabolic steroids. These websites have been excluded from our lists. 7 Additionally, we recognize that the suspension and termination of services by a single domain name registrar is not a permanent solution; the website operator may simply take his or her business to another domain name registrar. But an industry-wide commitment to terminate services to illicit pharmaceutical websites would make it more difficult for these websites to conduct a profitable business, put the rogue website operators on the defensive, and succeed in making illicit steroids less readily available over the Internet. Other Findings: Age Verification, Payment Mechanisms and Delivery Services The Internet presence of, and ability to access through a browser, a website illicitly selling steroids is the cornerstone that these rogue businesses rely on to survive and thrive. But two other dimensions are also important: how the businesses receive payment, and how the steroids are physically delivered to the customer from outside of the country. A more in-depth analysis of payment mechanisms and delivery services related to illicit steroid sites will be the subject of an upcoming report. For now, we note the following general findings: • Payment: Western Union appears to be the payment service of choice for most illicit steroid websites that we reviewed. Many websites displayed a Visa, MasterCard or American Express seal; although most did not in fact offer payment service through Visa or MasterCard, some illicit steroid sites actually did, and several also offered American Express as a payment option. • Delivery: Information about delivery services was not always apparent on the steroid website, but DHL appeared to be commonly used; in some cases, it appeared that the website would simply take the risk of sending the package through the normal postal service, counting on Customs inspectors to not inspect the package. Two other aspects of this problem are troubling and merit mention. The first is that none of the sites in this report maintained any sort of an age verification service. Studies indicate that youth, including high school students, are particularly at risk for steroid abuse ⎯ and the harms of steroid abuse may be aggravated for youth and young adults. The second is that the anabolic steroids sold on websites we reviewed typically purported to be from countries such as India, China, Turkey or Thailand; in several cases, either the individuals selling the steroids or the drugs themselves appeared to come from Eastern Europe or Russia. The lack of oversight by the Food and Drug Administration of these drugs’ manufacture and shipment provides yet another layer of 8 concern, as the products may contain adulterants or counterfeit substances additionally harmful to health. Discussion: Steroids on the Internet ⎯ What Can Be Done? The point of this report is that domain name registrars, especially those located in the US, have the ability and responsibility to shut down websites selling anabolic steroids without a prescription, even if those websites are registered to individuals located outside of the United States. In fact, absent law enforcement action by the host country, termination of website services by the domain name registrars is not just the best, but may be the only, solution to the problem. What about the contention ⎯ such as the one Excerpt from Enomʼs User Agreement: made by eNom in its email to us (see text box “...we and your Primary Service Provider to the right) ⎯ that the registrars cannot do may terminate or suspend the Service(s) at any time for cause, which, without limitation, anything about these sites? This is erroneous: includes...abuse of the Services, payment after all, the domain name registrars can irregularities, serious allegations of illegal certainly make websites inaccessible if the conduct…(or) unsolicited bulk email. website owner fails to pay their annual fee. eNomʼs Response to email from Moreover, the very terms of the User LegitScript and KnujOn alleging illegal Agreements indicate that the domain name conduct: “...due to the limited technical sphere in registrars reserve the right to terminate services which eNom operates, we do not believe that in specified circumstances ⎯ a contractual we are the correct party to contact regarding provision that would make no sense if the (these websites). In this instance, we suggest that you contact the party operating registrars lacked the technical ability to do so. the website or the party hosting the website And KnujOn has already observed numerous to have this matter properly instances where registrars terminated services resolved…” (email from eNom, July 1, 2008). for other reasons, such as “spam” email or “phishing.” To make a somewhat more graphic point: the domain name registrars, quite correctly, have no hesitation in terminating services in cases of child pornography. They should do the same for drug dealing, including the illicit sale of anabolic steroids. Our response from Dynadot regarding the website anabolics4fitness.com strongly suggests that the registrars will not act unless the request comes from a law enforcement agency ⎯ not a member of the public. The evidence we provided Dynadot about anabolics4fitness.com is, we think, overwhelming: the site says that is sells steroids; it has pictures of products on the site that have the name of prohibited steroids, and were in injectable vials; the website accepts payment; and we 9 submitted an email to Dynadot that we received from the website operator providing us with information about how to send payment via Western Union, including a bank account number, to an account in the Czech Republic in exchange for a Schedule III anabolic steroid. There is no conceivable reason not to terminate services to the website immediately. Yet Dynadot’s final response was that we needed to “refer this case to the FBI Cyber-crimes Unit and/or another government agency, and have them contact us so that we can work directly with the authorities towards resolution of this situation.”12 Meanwhile, the website remains active and available to do business with US residents, including underage adults. Photograph of anabolic steroid for sale from anabolics4fitness.com, a website registered to Dynadot (anabolics4fitness.com home page). The drugs are made in China. We provided proof to Dynadot that the website operator contacted us with an offer to sell this anabolic steroid for money to be sent to the Czech Republic. Dynadot has declined to terminate the website. (email from Dynadot to LegitScript). LegitScript and KnujOn agree that involvement by the DEA, FDA and FBI, and other agencies, is an indispensable component of a national strategy to fight online steroid abuse. But if the registrars refuse to act until and unless law enforcement asks them to do so, this is a fundamentally reactive strategy, and absolves the registrars from taking any proactive role in addressing this problem until the last possible moment. There is nothing in the law that requires registrars to wait until law enforcement orders them to terminate a website. Moreover, their User Agreements (or equivalent documents) reserve the right for the registrars to terminate these websites ⎯ and their refusal to do so unless law enforcement is involved suggests a disparity between their written policy and actual practice. What is more, this response by Dynadot fails to understand a stark reality: because the website operator is almost certainly overseas (in this case, in the Czech Republic), US law enforcement will typically face jurisdictional hurdles in becoming involved in the case at all. As a result, US law enforcement may (correctly) decline to investigate a case they do not easily have jurisdiction over, despite the fact that the website offers to sell to US residents. If the domain name registrar refuses to act unless contacted by law 12 email from Dynabotʼs Abuse Team, July 18, 2008. 10 enforcement, it is likely that these websites will continue to operate unimpeded ⎯ a result that contradicts both common sense as well as the domain name registrars’ contractual agreements and obligations. And what about the suggestion ⎯ again, put to us by domain name registrar eNom, as well as others ⎯ that the party “hosting the website” (meaning, the physical computer server where the website text, graphics and program actually resides) be contacted instead? Certainly, we agree that the hosting companies share responsibility. But unlike domain name registrars, which are subject to the oversight of an international organization (ICANN), hosting companies are usually private entities, and rogue pharmacy website operators can simply purchase their own computer servers to host the website content. Only the domain name registrars, as ICANN-accredited entities, have both the opportunity and internationally recognized responsibility to take affirmative action regarding these sort of websites. Moreover, we note the recent testimony of GoDaddy’s chief counsel, noting that in 2007, the company suspended 1,300 websites illicitly offering drugs for sale, the company’s stated willingness to continue doing so, and that the company uses its “terms of service broadly to cancel privacy (for website registration) when it is being used for ANY improper purpose” (emphasis in the original).13 (The ability to register a website privately, or anonymously, is commonly used by individuals registering rogue steroid websites to conceal their identity.) This indicates, of course, that GoDaddy, and presumably the other domain name registrars, have the ability and opportunity to terminate or suspend services for these websites and to remove the cloak of anonymity that enables illegal activity. As with the other registrars, the numerous websites we complained to GoDaddy about are still active, and as far as we can tell, anonymity has not been removed. What about the fact that anabolic steroids are actually legal without a prescription in some countries? Even if the seller is located in that country, and therefore not violating that country’s law, two things are clear: first, the drugs are being marketed and made available to residents of the United States, where the illegality of anabolic steroids, without a prescription, is well-established 14; and second, the domain name registrars in question, being physically located within the United States, should consider US law to 13 Online Pharmacies and the Problem of Internet Drug Abuse, Christine N. Jones, General Counsel and Corporate Secretary, The Go Daddy Group, Inc., before the House Committee on the Judiciary, Subcommittee on Crime, Terrorism and Homeland Security, US House of Representatives, June 24, 2008 14 For many websites we reviewed, the default shipping location when making a purchase is the United States. 11 define what is “illegal” for the purposes of the terms of their User Agreements, and take action accordingly. Finally, what is the responsibility of the International Commission on Assigned Names and Numbers (ICANN) here? In order to sell and register domain names, a domain name registrar must be accredited by ICANN; the organization should make clear to its accreditees that failure to terminate services to rogue pharmaceutical websites will result in the domain name registrars themselves losing their accreditation. To date, we are not aware of any instance in which ICANN has done this. Conclusion KnujOn.com and LegitScript.com recognize the important and unparalleled societal, business and health benefits offered by Internet companies, including domain name registrars and ⎯ when operating legitimately ⎯ pharmacy websites. We also recognize the medical value of steroids that may be legitimately prescribed pursuant to the existence of a legitimate doctor-patient (or, for animals, veterinary-client-patient) relationship. However, we are deeply troubled by the proliferation of websites offering anabolic steroids without any sort of medical supervision or the requirement for a valid prescription. When the individuals responsible for the sale of these products are located within the United States, the most obvious response would appear to be law enforcement action by the DEA. But as noted in our report, these sites are now evading DEA jurisdiction by being located outside of the country but using US-based domain name registrars. Nobody should expect the domain name registrars to police every single website in real time. However, identification of those websites should lead to the swift termination of services ⎯ a result that would make life more difficult for illicit sellers of anabolic steroids, disrupt the illicit online market for anabolic steroids, and set an important example for domain name registrars located outside of the United States. The domain name registrars we contacted still have the opportunity to act. As our nation continues to struggle with the implications of rising prescription drug abuse and steroid abuse, and the Internet’s role in that problem, we are hopeful that they will do so. 12 In developing this report, LegitScript and KnujOn jointly researched and identified websites that offer anabolic steroids without a valid prescription to customers within the United States. LegitScriptʼs standards for pharmacy website legitimacy were used as the baseline against which the websitesʼ operations were evaluated, and LegitScript brought its expertise regarding Internet pharmacy evaluations to this report. KnujOn brought its experience and expertise in identifying the domain registrars, analyzing the registrarsʼ User Agreements and contractual requirements with the International Commission on Assigned Names and Numbers (ICANN) and in identifying websites engaged in unlawful behavior. Information about LegitScript is available at www.legitscript.com. Information about KnujOn is available at www.knujon.com. 13 In developing this report, LegitScript and KnujOn jointly researched and identified websites that offer anabolic steroids without a valid prescription to customers within the United States. LegitScriptʼs standards for pharmacy website legitimacy were used as the baseline against which the websitesʼ operations were evaluated, and LegitScript brought its expertise regarding Internet pharmacy evaluations to this report. KnujOn brought its experience and expertise in identifying the domain registrars, analyzing the registrarsʼ User Agreements and contractual requirements with the International Commission on Assigned Names and Numbers (ICANN) and in identifying websites engaged in unlawful behavior. Information about LegitScript is available at www.legitscript.com. Information about KnujOn is available at www.knujon.com. 13 Appendix A: Federal laws and regulations related to Anabolic Steroids Federal law defines anabolic steroids as Schedule III controlled substances. (21 USC 812 (Schedule III (e)). Schedule III drugs are considered harmful because "(a)buse of the drug or other substance may lead to moderate or low physical dependence or high psychological dependence." 21 U.S.C. § 812(b)(3). The Code of Federal Regulations lists the specific substances that are considered anabolic steroids under Federal law (21 CFR 1300.01(b)(4)). However, the actual products may have a variety of trade names. Substances classified as anabolic steroids under 21 CFR 1300.01(b)(4) cannot be possessed or distributed under Federal law, and every state law, without a valid prescription. (21 USC 829(b)) 21 CFR 1300.01(b)(4) lists the following substances as Anabolic Steroids. 21 CFR 1300.01(b)(4): The term anabolic steroid means any drug or hormonal substance, chemically and pharmacologically related to testosterone (other than estrogens, progestins, corticosteroids, and dehydroepiandrosterone), and includes: (i) 3[beta],17-dihydroxy-5a-androstane (ii) 3[alpha],17[beta]-dihydroxy-5a-androstane (iii) 5[alpha]-androstan-3,17-dione (iv) 1-androstenediol (3[beta],17[beta]-dihydroxy-5[alpha]-androst-1ene) (v) 1-androstenediol (3[alpha],17[beta]-dihydroxy-5[alpha]-androst-1ene) (vi) 4-androstenediol (3[beta],17[beta]-dihydroxy-androst-4-ene) (vii) 5-androstenediol (3[beta],17[beta]-dihydroxy-androst-5-ene) (viii) 1-androstenedione ([5[alpha]]-androst-1-en-3,17-dione) (ix) 4-androstenedione (androst-4-en-3,17-dione) (x) 5-androstenedione (androst-5-en-3,17-dione) (xi) bolasterone (7[alpha],17[alpha]-dimethyl-17[beta]-hydroxyandrost4-en-3-one) (xii) boldenone (17[beta]-hydroxyandrost-1,4,-diene-3-one) 14 (xiii) calusterone (7[beta],17[alpha]-dimethyl-17[beta]-hydroxyandrost4-en-3-one) (xiv) clostebol (4-chloro-17[beta]-hydroxyandrost-4-en-3-one) (xv) dehydrochloromethyltestosterone (4-chloro-17[beta]-hydroxy17[alpha]-methyl-androst-1,4-dien-3-one) (xvi) [Delta]1-dihydrotestosterone (a.k.a. '1-testosterone') (17[beta]hydroxy-5[alpha]-androst-1-en-3-one) (xvii) 4-dihydrotestosterone (17[beta]-hydroxy-androstan-3-one) (xviii) drostanolone (17[beta]-hydroxy-2[alpha]-methyl-5[alpha]androstan-3-one) (xix) ethylestrenol (17[alpha]-ethyl-17[beta]-hydroxyestr-4-ene) (xx) fluoxymesterone (9-fluoro-17[alpha]-methyl-11[beta],17[beta]dihydroxyandrost-4-en-3-one) (xxi) formebolone (2-formyl-17[alpha]-methyl-11[alpha],17[beta]dihydroxyandrost-1,4-dien-3-one) (xxii) furazabol (17[alpha]-methyl-17[beta]-hydroxyandrostano[2,3-c]furazan) (xxiii) 13[beta]-ethyl-17[beta]-hydroxygon-4-en-3-one (xxiv) 4-hydroxytestosterone (4,17[beta]-dihydroxy-androst-4-en-3-one) (xxv) 4-hydroxy-19-nortestosterone (4,17[beta]-dihydroxy-estr-4-en-3one) (xxvi) mestanolone (17[alpha]-methyl-17[beta]-hydroxy-5-androstan-3one) (xxvii) mesterolone (1[alpha]methyl-17[beta]-hydroxy-[5[alpha]]androstan-3-one) (xxviii) methandienone (17[alpha]-methyl-17[beta]-hydroxyandrost-1,4dien-3-one) (xxix) methandriol (17[alpha]-methyl-3[beta],17[beta]-dihydroxyandrost5-ene) (xxx) methenolone (1-methyl-17[beta]-hydroxy-5[alpha]-androst-1-en-3one) (xxxi) 17[alpha]-methyl-3[beta], 17[beta]-dihydroxy-5a-androstane (xxxii) 17[alpha]-methyl-3[alpha],17[beta]-dihydroxy-5a-androstane 15 (xxxiii) 17[alpha]-methyl-3[beta],17[beta]-dihydroxyandrost-4-ene (xxxiv) 17[alpha]-methyl-4-hydroxynandrolone (17[alpha]-methyl-4hydroxy-17[beta]-hydroxyestr-4-en-3-one) (xxxv) methyldienolone (17[alpha]-methyl-17[beta]-hydroxyestra-4,9(10)dien-3-one) (xxxvi) methyltrienolone (17[alpha]-methyl-17[beta]-hydroxyestra-4,911-trien-3-one) (xxxvii) methyltestosterone (17[alpha]-methyl-17[beta]-hydroxyandrost4-en-3-one) (xxxviii) mibolerone (7[alpha],17[alpha]-dimethyl-17[beta]-hydroxyestr4-en-3-one) (xxxix) 17[alpha]-methyl-[Delta]1-dihydrotestosterone (17b[beta]hydroxy-17[alpha]-methyl-5[alpha]-androst-1-en-3-one) (a.k.a. '17[alpha]-methyl-1-testosterone') (xl) nandrolone (17[beta]-hydroxyestr-4-en-3-one) (xli) 19-nor-4-androstenediol (3[beta], 17[beta]-dihydroxyestr-4-ene) (xlii) 19-nor-4-androstenediol (3[alpha], 17[beta]-dihydroxyestr-4-ene) (xliii) 19-nor-5-androstenediol (3[beta], 17[beta]-dihydroxyestr-5-ene) (xliv) 19-nor-5-androstenediol (3[alpha], 17[beta]-dihydroxyestr-5-ene) (xlv) 19-nor-4-androstenedione (estr-4-en-3,17-dione) (xlvi) 19-nor-5-androstenedione (estr-5-en-3,17-dione (xlvii) norbolethone (13[beta], 17[alpha]-diethyl-17[beta]-hydroxygon4-en-3-one) (xlviii) norclostebol (4-chloro-17[beta]-hydroxyestr-4-en-3-one) (xlix) norethandrolone (17[alpha]-ethyl-17[beta]-hydroxyestr-4-en-3one) (l) normethandrolone (17[alpha]-methyl-17[beta]-hydroxyestr-4-en-3-one) (li) oxandrolone (17[alpha]-methyl-17[beta]-hydroxy-2-oxa-[5[alpha]]androstan-3-one) (lii) oxymesterone (17[alpha]-methyl-4,17[beta]-dihydroxyandrost-4-en3-one) (liii) oxymetholone (17[alpha]-methyl-2-hydroxymethylene-17[beta]hydroxy-[5[alpha]]-androstan-3-one) 16 (liv) stanozolol (17[alpha]-methyl-17[beta]-hydroxy-[5[alpha]]androst-2-eno[3,2-c]-pyrazole) (lv) stenbolone (17[beta]-hydroxy-2-methyl-[5[alpha]]-androst-1-en-3one) (lvi) testolactone (13-hydroxy-3-oxo-13,17-secoandrosta-1,4-dien-17-oic acid lactone) (lvii) testosterone (17[beta]-hydroxyandrost-4-en-3-one) (lviii) tetrahydrogestrinone (13[beta], 17[alpha]-diethyl-17[beta]hydroxygon-4,9,11-trien-3-one) (lix) trenbolone (17[beta]-hydroxyestr-4,9,11-trien-3-one) (xiii)Any salt, ester, or ether of a drug or substance described in this paragraph. Except such term does not include an anabolic steroid that is expressly intended for administration through implants to cattle or other nonhuman species and that has been approved by the Secretary of Health and Human Services for such administration. If any person prescribes, dispenses, or distributes such steroid for human use, the person shall be considered to have prescribed, dispensed, or distributed an anabolic steroid within the meaning of this paragraph. 17 Appendix B: Domain Name Registrar Report: ICANN Responsibilities All Registrars, and by agreement registrants, must follow the Internet Corporation of Assigned Names and Numbers Registrar Accreditation Agreement which states, in relevant part: 3.7.2 Business Dealings, Including with Registered Name Holders. Registrar shall abide by applicable laws and governmental regulations. and, 3.8 Registrar shall comply with the Uniform Domain Name Dispute Resolution Policy (see below). The Uniform Domain Name Dispute Resolution Policy states all registrants must affirm that: 2(c) you are not registering the domain name for an unlawful purpose; 2(d) you will not knowingly use the domain name in violation of any applicable laws or regulations. 18 Appendix C: Registrar User Agreements and Replies As noted in the body of this report, a full listing of the websites in question and the User Agreements (or equivalent documents) that prohibit illegal activity are located at www.knujon.com/schedule3/dir.html, and at www.legitscript.com/steroidreport.html. The hyperlinks for each website do not link to the website itself, but rather a .pdf file of each website as it existed shortly after the time that LegitScript and KnujOn reviewed the website. Below, we have provided information about each of the eight domain name registrars; the registrar’s technical and contractual ability to prevent a domain name from resolving; the obligation that each domain name registrar has regarding illegal activity pursuant to their status as an ICANN-accreditee, and the response from each domain name registrar. Each registrar has the technical ability to prevent a domain name from resolving by deleting the record or placing the website on “hold.” 19 ABACUS AMERICA, INC Aplus.Net Internet Services 7500 W 110th St., Suite 400 Overland Park, KS 66210 Terms of Service Violated “It is contrary to Aplus.Net policy for any user of any of these services to effect or participate in any of the following activities through an Aplus.Net- provided service: 7.5. Promoting or providing information about illegal activities” 24. Terms. PROVIDER can terminate this agreement at the end of a billing period, with a 30 days notice. PROVIDER can terminate the agreement immediately without any compensation if CLIENT does not comply with the "Acceptable use policy" available online at this address http://www.aplus.net/use.html." 29. Governing Law. This Agreement was entered into in the State of California and its validity, construction, interpretation and legal effect shall be governed by the laws and judicial decisions of the State of California applicable to contracts entered into and performed entirely within the State of California." Response to Request to Terminate Offending Website: None. Website status: Active. Domain Name multihgroup.com IP address 216.55.145.250 Notes about website: LegitScript received an email from said website operator offering anabolic steroids in exchange for payment. 20 Registrar DSTR ACQUISITION VII, LLC PO Box 821067 Vancouver, WA 98682 Terms of Service Violated Domain Bank and its designees shall have the right (but not the obligation) in their sole discretion to refuse or move any Content that is available via our services. Without limiting the foregoing, Domain Bank and its designees shall have the right to remove any Content that violates this Registration Agreement or is otherwise objectionable. Further, you acknowledge and agree that Domain Bank may preserve Content and may also disclose such Content if required to do so by law or upon the good faith belief that such preservation or disclosure is reasonably necessary to: (a) comply with legal process; (b) enforce this Registration Agreement; (c) respond to claims that any Content violates the rights of third-parties; or (d) protect the rights, property, or personal safety of Domain Bank, its users and the public. … You agree to: (n.) not intentionally or unintentionally violate any applicable local, state, national or international law… “16. Term and termination: 16.3 Termination. Domain Bank reserves the right to suspend, cancel, transfer or modify your domain registration if: (c) you use your domain in connection with unlawful activity;” Domain Name IP address aol-vip.com** 203.174.81.170 e-anabolics.com ! 203.174.81.170 ** Website is the password protected login for anabolics-online.com, a steroids website. ! This website has alternately been up and then down over the last several weeks. Terms of Service Violated Domain Bank and its designees shall have the right (but not the obligation) in their sole discretion to refuse or move any Content that is available via our services. Without limiting the foregoing, Domain Bank and its designees shall have the right to remove any Content that violates this Registration Agreement or is otherwise objectionable. 21 Further, you acknowledge and agree that Domain Bank may preserve Content and may also disclose such Content if required to do so by law or upon the good faith belief that such preservation or disclosure is reasonably necessary to: (a) comply with legal process; (b) enforce this Registration Agreement; (c) respond to claims that any Content violates the rights of third-parties; or (d) protect the rights, property, or personal safety of Domain Bank, its users and the public. … You agree to: (n.) not intentionally or unintentionally violate any applicable local, state, national or international law… “16. Term and termination: 16.3 Termination. Domain Bank reserves the right to suspend, cancel, transfer or modify your domain registration if: (xiv)you use your domain in connection with unlawful activity;” Response to Request to Terminate Offending Websites: None. Website status: Active. 22 Registrar dynadot.com PO Box 345 San Mateo, CA 94401 Terms of Service Violated “7. RIGHT OF REFUSAL; CANCELLATION OF SERVICES; ACCEPTABLE USE POLICY. Morally objectionable activities include, but are not limited to, … activities prohibited by the laws of the United States and/or foreign territories in which You conduct business;” Response to Request to Terminate Offending Websites: “Hello, Thank you very much for submitting your complaint and accompanying evidence regarding this matter. Our Legal Department asks that you refer this case to the FBI Cyber-crimes Unit and/or another government agency, and have them contact us so that we can work directly with the authorities towards resolution of this situation. Thank you again for contacting Dynadot. Best Regards, Dynadot Staff” Website status: Active. Domain Name anabolics4fitness.com IP address 77.78.110.43 Notes about website: LegitScript investigated website and corresponded with website operator, who offered anabolic steroids in exchange for money. 23 Registrar Everyones Internet, Ltd. dba resellone.net 315 Capitol Suite 205 Houston Texas 77002 Terms of Service Violated “1. Compliance with laws. You may not use the Service in any way that violates applicable state, federal or international laws, regulations or other government requirements. Prohibited activities include * Fraud. * Using the Service to make fraudulent offers to sell or buy products” “3. Objectionable content. You may not use the Service to post, transmit, distribute, or store any content, or provide links to any external Internet site that contains content that in PeoplePC's judgment is illegal, inappropriate, or otherwise objectionable. This includes: Content that PeoplePC determines to be otherwise objectionable or harmful to PeoplePC's reputation and brand image” Response to Request to Terminate Offending Websites: None. Website status: Active. Domain Name aanabolic.com IP address 88.198.202.99 24 Registrar eNom, Inc. 15801 NE 24th Street Bellevue Washington 98006 Terms of Service Violated 12. You represent and warrant as follows: … c) that your website and your use of the Services will not violate any laws, including, without limitation, laws relating to unsolicited commercial email, child pornography, collection of identifying information, consumer protection, and privacy… 19. GOVERNING LAW: this Agreement, your rights and obligations and all actions contemplated by this Agreement shall be governed by the laws of the United States of America and the State of Washington, as if the Agreement was a contract wholly entered into and wholly performed within the State of Washington. … Domain Name IP address airsealed.com 83.223.116.240 anabolicsteroidsaccess.com 217.26.212.7 anabolicsteroidsaction.com 217.26.212.20 anabolicsteroidsavenue.com 217.26.212.7 anabolicsteroidspharma.com 217.26.212.7 lookformeds.com 217.26.212.4 pharma-active.com* 217.26.212.4 synthethic-androgen.com 70.86.24.154 * Site is active but no content was found ** Site is member-only/password protected ! Site appears suspended By registering a domain name or applying for other Service(s) you also represent that the statements in your application are true and you also represent that the domain name is not being registered or the Services being procured for any unlawful purpose.” “You agree you shall use the Company's services only for lawful purposes.” (Shared Hosting Master Service Agreement.) Response to Request to Terminate Offending Websites: “After researching the other domains, we have found that eNom, Inc. only provides domain name registration for these domains. We are not the webhost, internet service provider, or administrator for the domains. Given that we are not the webhost for the domain, the material identified in your notification does not reside on eNomʼs computer servers. Accordingly, we do not have the technical ability to remove or disable specific items of objectionable content. Again, due to the limited technical sphere in which eNom operates, we do not believe that we are the correct party to contact regarding this matter. In this instance, we suggest that you contact the party operating the website or the party hosting the website 25 to have this matter properly resolved. A "ping" of the website you indicated often reveals the IP number of the party which probably hosts this website. You may then use http:// www.arin.net/whois/ or another similar tool to identify this party.” Website status: Active/unchanged. Notes on websites: The website pharma-active.com simply displays “coming soon” text. However, given the name of the site and the fact that is shares an IP address with anabolic steroid selling sites ⎯ and is the only other website on that IP address we found not active ⎯ and is also registered to the same individual controlling the other sites, we think that this is a “backup site” for anabolic steroids and should be treated the same. 26 Registrar EstDomains, Inc 110 W. Ninth Street #688 Wilmington Delaware Terms of Service Violated "2. Terms of USAGE OF OrderBox (1) Customer, or its contractors, employees, directors, officers, representatives, agents and affiliates and OrderBox Users, either directly or indirectly, shall not use or permit use of the OrderBox, directly or indirectly, in violation of any federal, state or local rule, regulation or law, or for any unlawful purpose (9) Using OrderBox directly or indirectly for any of the below activities activities: (15)Unlawful or illegal activities of any kind" Domain Name IP address anasteroid.com ! 87.118.122.122 sale-steroids.com ! 87.118.122.122 topanabolics.com ! 87.118.122.122 fitnesspharmaas.com 208.113.151.229 * Site is active but no content was found ** Site is member-only/password protected ! Site appears suspended 27 Registrar GoDaddy 14455 N. Hayden Rd. Suite 219 Scottsdale, AZ 85260 Terms of Service Violated 5. NO UNLAWFUL CONDUCT OR IMPROPER USE. As a condition of Your use of Go Daddy ʼs Software and Services, You agree not to use them for any purpose that is unlawful or prohibited by these terms and conditions, and You agree to comply with any applicable local, state, federal and international laws, government rules or requirements. … Go Daddy reserves the right at all times…to edit, refuse to post or to remove any information or materials, in whole or in part, in Go Daddy's sole discretion. Go Daddy reserves the right to review Your use of the Services and to cancel the Services in its sole discretion. Go Daddy reserves the right to terminate Your access to the Services at any time, without notice, for any reason whatsoever. Except as set forth below, Go Daddy may also cancel Your use of the Services, after thirty (30) days, if You are using the Services, as determined by Go Daddy in its sole discretion, in association with spam or morally objectionable activities. Morally objectionable activities will include, but not be limited to: … activities prohibited by the laws of the United States and/or foreign territories in which You conduct business; activities designed to encourage unlawful behavior by others, such as hate crimes, terrorism and child pornography; … and activities designed to harm or use unethically minors in any way.” Response to Request to Terminate Offending Websites: None. Website status: Active. Domain Name Registrar IP address 1abcpharma.com WILD WEST 217.26.209.2 abs365.com WILD WEST 217.26.212.20 abspharmacy.com* WILD WEST 217.26.212.20 28 Domain Name Registrar IP address admiralmeds.com WILD WEST 217.26.212.7 anabolicpharmaeurope.com WILD WEST 77.78.110.43 anaboliceurope.com WILD WEST 217.26.212.4 anabolic-power.com WILD WEST 217.26.212.4 anabolic-steroids.net WILD WEST 217.26.212.22 anabolicsteroidsuccess.com WILD WEST 217.26.212.7 arimiplex.com GODADDY 72.36.245.18 arimiplex.net GODADDY 72.36.245.18 AXHOST.ORG GODADDY 73.36.218.90 axiolabsgear.com GODADDY 81.223.243.114 b3slabs.com GODADDY 84.16.252.25 bestoralsteroids.com GODADDY 91.185.201.174 bodybolics.com GODADDY 217.26.212.21 body-pharmacy.com GODADDY 217.26.212.21 buildmeds.com* WILD WEST 217.26.212.7 buybestanabolicsteroids.com GODADDY 91.185.201.174 buyclenbuterol.net GODADDY 91.185.201.174 buysteroidsuk.com WILD WEST 203.142.28.99 buysustanon.info GODADDY 98.130.42.2 buysustanon.org GODADDY 91.185.201.174 buywinstrol.net GODADDY 91.185.201.174 capital-pharmacy.com GODADDY 212.72.99.59 clenbutaplex.com GODADDY 72.36.245.18 29 Domain Name Registrar IP address clomiplex.com GODADDY 72.36.245.18 clomiplex.net GODADDY 72.36.245.18 decaplex.net GODADDY 72.36.245.18 decaplex275.com GODADDY 72.36.245.18 duraplex.net GODADDY 72.36.245.18 duraplex100.com GODADDY 72.36.245.18 duraplex100.net GODADDY 72.36.245.18 effectivemedications.com GODADDY 91.185.201.174 equiplex200.com GODADDY 72.36.245.18 euromuskeln.com GODADDY 84.51.37.223 europeandispensary.net* GODADDY 217.26.212.21 eurosteroids.com GODADDY 217.26.212.21 extra-body.com GODADDY 217.26.212.21 haloplex.com GODADDY 72.36.245.18 haloplex.net GODADDY 72.36.245.18 ianadrol.com GODADDY 69.10.143.180 isteroids.com GODADDY 69.10.143.190 ivitamins.org GODADDY 202.67.154.151 letroplex.com GODADDY 72.36.245.18 letroplex.net GODADDY 72.36.245.18 mastaplex.com GODADDY 72.36.245.18 mastaplex.net GODADDY 72.36.245.18 mastaplex100.com GODADDY 72.36.245.18 30 Domain Name Registrar IP address mastaplex100.net GODADDY 72.36.245.18 mastaplex200.com GODADDY 72.36.245.18 mastaplex200.net GODADDY 72.36.245.18 meds-shop.org GODADDY 217.26.212.21 methanoplex.com GODADDY 72.36.245.18 methanoplex.net GODADDY 72.36.245.18 methanoplex10.com GODADDY 72.36.245.18 methanoplex10.net GODADDY 72.36.245.18 methanoplex50.com GODADDY 72.36.245.18 methanoplex50.net GODADDY 72.36.245.18 muscle-medications.com* GODADDY 217.26.209.2 mynet-pay.com* GODADDY 217.26.212.4 normshop.net GODADDY 217.26.212.21 oxandroplex.com GODADDY 72.36.245.18 oxandroplex.net GODADDY 72.36.245.18 oxyplex.net GODADDY 72.36.245.18 pharmabolic.com WILD WEST 217.26.212.20 pharmacy-united.com* WILD WEST 217.26.212.4 pharmanabolics.com WILD WEST 80.65.160.27 pharmastate.com WILD WEST 217.26.212.4 pharma-state.com* GODADDY 217.26.212.21 primoplex.com GODADDY 72.36.245.18 primoplex.net GODADDY 72.36.245.18 31 Domain Name Registrar IP address primoplex100.com GODADDY 72.36.245.18 primoplex100.net GODADDY 72.36.245.18 primoplex25.com GODADDY 72.36.245.18 primoplex25.net GODADDY 72.36.245.18 proviraplex.com GODADDY 72.36.245.18 proviraplex.net GODADDY 72.36.245.18 roid4sale.com GODADDY 217.26.212.21 roid4sale.net GODADDY 209.97.196.4 sildenaplex.com GODADDY 72.36.245.18 sildenaplex.net GODADDY 72.36.245.18 sildenaplex100.com GODADDY 72.36.245.18 sildenaplex100.net GODADDY 72.36.245.18 stanaplex.com GODADDY 72.36.245.18 stanaplex.net GODADDY 72.36.245.18 stanaplex50.com GODADDY 72.36.245.18 stanaplex50.net GODADDY 72.36.245.18 stanoplex.com GODADDY 72.36.245.18 stanoplex.net GODADDY 72.36.245.18 stanoplex10.com GODADDY 72.36.245.18 stanoplex10.net GODADDY 72.36.245.18 stanoplex50.com GODADDY 72.36.245.18 stanoplex50.net GODADDY 72.36.245.18 steroidplex.com* GODADDY 72.36.218.90 32 Domain Name Registrar IP address steroidsconnectionmarket.com GODADDY 217.26.212.4 steroidsland.com GODADDY 72.36.218.94 steroidspharmacy.net GODADDY 72.36.218.90 steroidsplex.com GODADDY 72.36.218.90 steroids-shop.net GODADDY 72.36.218.90 steroidstation.com WILD WEST 217.26.212.20 sustaplex.net GODADDY 72.36.245.18 sustaplex325.com GODADDY 72.36.245.18 sustaplex325.net GODADDY 72.36.245.18 syntropin.net GODADDY 72.36.245.18 taldenaplex.com GODADDY 72.36.245.18 taldenaplex.net GODADDY 72.36.245.18 taldenaplex20.com GODADDY 72.36.245.18 taldenaplex20.net GODADDY 72.36.245.18 tamoxiplex.com GODADDY 72.36.245.18 tamoxiplex.net GODADDY 72.36.245.18 testaplex.com GODADDY 72.36.245.18 testaplex.net GODADDY 72.36.245.18 testaplexc200.com GODADDY 72.36.245.18 testaplexc200.net GODADDY 72.36.245.18 testaplexe250.com GODADDY 72.36.245.18 testaplexe250.net GODADDY 72.36.245.18 testaplexp100.com GODADDY 72.36.245.18 33 Domain Name Registrar IP address testaplexp100.net GODADDY 72.36.245.18 testaplexp50.com GODADDY 72.36.245.18 testaplexp50.net GODADDY 72.36.245.18 trenaplex.com GODADDY 72.36.245.18 trenaplex.net GODADDY 72.36.245.18 trenaplexa100.com GODADDY 72.36.245.18 trenaplexa100.net GODADDY 72.36.245.18 trenaplexd100.com GODADDY 72.36.245.18 trenaplexd100.net GODADDY 72.36.245.18 trenaplexe200.com GODADDY 72.36.245.18 trenaplexe200.net GODADDY 72.36.245.18 trinaplex.com GODADDY 72.36.245.18 trinaplex.net GODADDY 72.36.245.18 trinaplex200.com GODADDY 72.36.245.18 tri-trenabolestore.com GODADDY 72.36.245.18 turanaplex.net GODADDY 72.36.245.18 underground-pharmacy.com GODADDY 217.26.212.21 wholesalesteroids.com** WILD WEST 212.72.99.59 34 Registrar Parava Networks, Inc. dba 10-Domains.com 5444 Westheimer Road Suite #1585 Houston, TX Domain Name IP address buionpharmacie.com 200.2.204.171 medpharmacare.com 200.2.204.171 ortpharmacy.com 200.2.204.182 Terms of Service Violated 4.2 ANTI SPAM POLICY. Except as set forth below, Parava Networks may also cancel Your use of the Services, after thirty (30) days, if You are using the Services in association with spam or morally objectionable activities. Morally objectionable activities will include, but not be limited to: activities designed to defame, embarrass, harm, abuse, threaten, slander or harass third parties; activities prohibited by the laws of the United States and/or foreign territories in which You conduct business… Response to Request to Terminate Offending Websites: None. Website status: Active. 35