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**Stemming the Growing Tide of Rogue Online Pharmacies**

The Internet is an increasingly important channel for the efficient and
effective distribution of prescription drugs. Legitimate online
pharmacies, such as drugstore.com™, are serving the growing numbers of
online consumers by providing a safe, reliable, and cost-effective
online drugstore. drugstore.com™ enables individuals to learn about
their prescriptions, compare prices, learn about their potential drug
interactions, research frequently asked questions of its clinical
pharmacist staff and purchase their prescriptions \-- all with a simple
"point and click" on their computer.

Unfortunately, an alarming number of bad actors are posing as legitimate
online pharmacies, confusing U.S. consumers and providing them with
unsafe and illegal prescription drugs, including addictive narcotic
drugs. These 'rogue' online pharmacies are bypassing the doctor/patient
relationship in order to provide medications without an actual
prescription. These illegal (often offshore) pharmacies are a serious
threat to health and public safety and may provide consumers with
pharmaceuticals that could be expired, diluted, contaminated, or even
replaced with counterfeit medications.

drugstore.com™ ensures it meets the highest online pharmacy
certification standards as one of the first online pharmacies to be
awarded VIPPS® certification from the National Association of Boards of
Pharmacy® (NAPB®). Pharmacies displaying the VIPPS® seal on their
website are in compliance with licensing and inspection requirements of
their state and each state to which they dispense pharmaceuticals, as
well as with stringent pharmacy practice criteria established by NAPB®.

drugstore.com™ is reaching out to policymakers to be part of the
solution in stemming the growing tide of illegal drugs imported into the
United States by rogue online pharmacies. We are advocating a
three-stemmed approach to stopping these bad actors in their tracks and
in making the Internet safe for prescription shoppers.

-   Create a uniform certification standard

    -   Adopt VIPPS® or other standard to ensure certain regulations are
        met such as:

        -   No re-importation of prescription drugs

        -   Must meet doctor/patient relationship as endorsed by AMA

        -   Must meet all state/federal regulations for operating as
            online pharmacy

        -   Certification must be prominently displayed for consumers

-   Make it illegal for online pharmacies to advertise on search engines
    unless they meet approved standard

    -   Prohibit search engines from accepting advertisements from
        online pharmacies unless they were properly certified

    -   Make it illegal to advertise that you do not need doctor's
        prescription to get medication since that would not meet
        certification.

-   Stop credit card payment to pharmacies who do not meet certification
    standard above (i.e. illegal pharmacies)

    -   Similar to effort by Congress to starve funding of illegal
        Internet gambling sites, stopping credit card payment to illegal
        pharmacies would stop these rogue sites at the source.

    -   As with Internet gambling, by definition, the activities of
        these rogue pharmacies are illegal under U.S. law and should be
        stopped. Stemming the flow of funds to these sites will largely
        help to accomplish that goal.

-   Motivate third party shippers to not accept illegal shipments from
    pharmacies who do not meet the certification standard above

    -   One of the benefits of a clear certification standard -- is that
        the e-commerce enablers (media, payment, delivery) all can
        identify legitimate pharmacies vs. illegal operators

As rogue Internet pharmacies are investigated by the U.S. Congress,
drugstore.com stands ready to act as a resource in finding the best
solution to this compounding issue. U.S. consumers should feel confident
that the online marketplace is as safe and secure as possible,
especially with purchases as important to public heath as prescription
drugs. We are confident that the three-tiered approach outlined above
are the areas necessary to deal most effectively with this growing
public health problem.