conducted large pill-mill investigations with names like Operation Baywatch, Operation CyberRx, Operation Lightning Strike, and Operation Control/Alt/ Delete. See Michael Leonhart, DEA Administrator, "Warning: The Growing Danger of Prescription Drug Diversion," Statement before the U.S. House of Representatives, April 14, 2011.

7 Minnesota, Texas, and Illinois: The three pharmacies in question were, respec- tively: Ross-West Bank Pharmacy in Minneapolis, El Rancho Pharmacy in Dallas, and La Joya Drug in Chicago.

7 routine inspections: It was not unusual for diversion investigators to show up at pharmacies to examine their record-keeping procedures and how well they were securing drugs on site.

7 hundreds of similar websites: Nearly all of RX Limited's hundreds of affiliated sites are no longer active online. But snapshots of the sites and information about them—including Acmemeds.com—are available through the Internet Archive's Wayback Machine (web.archive.org) or through the work of watch- dog organizations including LegitScript and the Spamhaus Project.

8 "Open your own online pharmacy": RX Limited would also supply affiliates with out-of-the-box templates for their websites.

8 sending spam email: At one point, the Spamhaus Project, a nonprofit organiza- tion which tracks the largest email spammers on the Internet so that services can block them, would estimate that RX Limited-associated sites were re- sponsible for 25 percent of the spamming sites on their block list. Spamhaus Register of Known Operations, November 2010.

8 Ultram . . . was developing a reputation for abuse: See, for example, Max Siegelbaum and Alessandro Accorsi, "Egypt's Wave of Painkiller Addiction," Al Jazeera, November 29, 2013, and Justin Scheck, "Tramadol: The Opioid Crisis for the Rest of the World," The Wall Street Journal, October 19, 2016.

8 the Controlled Substances Act: 21 U.S. Code § 812.

9 lack any medical application: This purely legal categorization is often subject to significant scientific dispute, especially in the case of marijuana, ecstasy, and LSD—all Schedule I drugs that have been shown to have viable medical ap- plications. See, for example, David Nutt et al., "Effects of Schedule I drug laws on neuroscience research and treatment innovation," Nature Reviews Neuro- science 14 (2013), at 577-83.

9 wasn't entirely clear: This question would later become a central—if confusing— one in the prosecution of RX Limited. The DEA had specifically exempted Fioricet from some of its civil drug regulations (21 C.F.R. § 1308.32). Whether that exemption applied to potentially criminal distribution of Fioricet was a battle that would be fought over years (see USA v. Berkman, Document 1045, August 17, 2017).

9 "Our company is committed": USA v. Berkman, Document 1004, February 8, 2017, at 234.

10 seventy-two million doses: Interview with Kimberly Brill.

11 a hotel in Manila: Interview with Steven Holdren.