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tively assess using audio/video consultation but the providers have to implement these technologies. I am telling these guys to change to an audio/video technology but not sure if and when they will improve the system."

Later, he would point out that in sending the email he was act- ing against his own financial interests, risking losing the commis- sion he got after every prescription Konakanchi wrote. But as it turned out, he didn't. Konakanchi decided to keep filling prescrip- tions for RX Limited anyway, which meant that even after Tum- pati left the organization, he continued racking up his commissions.

Charles Schultz was in too deep—and too stubborn in his belief that the work was legal—to heed the warning signs. By the end of 2011, his two pharmacies had shipped more than 700,000 pre- scriptions. AlphaNet had wired more than $27 million from vari- ous accounts in Hong Kong to Schultz's bank—$3.3 million of which was Schultz's profits from his per-prescription fees. "He thought he'd found a way to sustain his business," Hal Harlowe, his lawyer, said. "He's a decent man who pursued what he thought was a legitimate opportunity but turned a blind eye to the cues that some of the people he was dealing with were, at best, walking along the edge of the law. These folks ran circles around him."

At first there were only small indications of trouble. The num- ber of daily prescriptions had begun declining, from a peak of fifteen hundred a day to eight hundred. The technicians and phar- macists were told to stop shipping drugs to customers in Wiscon- sin, so they flagged any in-state orders and rejected them in the system. Then, in June 2011, Schultz Pharmacy received a letter from the FedEx legal department. "It has come to our understand- ing that you are an online pharmacy," it read, "or that pharma- ceuticals purchased through online pharmacies are being shipped on your account." If the pharmacy couldn't provide evidence that the system was VIPPS-accredited—officially approved as legiti- mate by the National Association of Boards of Pharmacy—the ac-

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