1

U.S. Department of Justice

Drug Enforcement Administration

Schedules of Controlled Substances: Placement of (1-pentyl-1H-indol-3-yl)(2,2,3,3-

tetramethylcyclopropyl)methanone (UR-144), [1-(5-fluoro-pentyl)-1H-indol-3-yl](2,2,3,3-

tetramethylcyclopropyl)methanone (5-fluoro-UR-144, XLR11), and N-(1-adamantyl)-1-pentyl-1Hindazole-3-carboxamide (APINACA, AKB48) into Schedule I

Background, Data, and Analysis:

Eight Factors Determinative of Control and Findings Pursuant to 21 U.S.C. 812(b)

Prepared by 

Office of Diversion Control, Drug and Chemical Evaluation Section

Washington, D.C. 20537

May 2015
2

I. Background

On April 12, 2013, the Deputy Administrator of the Drug Enforcement Administration 

(DEA) published a Notice of Intent to temporarily place (1-pentyl-1H-indol-3-yl)(2,2,3,3-

tetramethylcyclopropyl)methanone (UR-144), [1-(5-fluoro-pentyl)-1H-indol-3-yl](2,2,3,3-

tetramethylcyclopropyl)methanone (5-fluoro-UR-144, XLR11), and N-(1-adamantyl)-1-pentyl1H-indazole-3-carboxamide (APINACA, AKB48) into schedule I pursuant to the temporary 

scheduling provisions of the CSA (78 FR 21858). On May 16, 2013, the Deputy Administrator 

published a Final Order in the Federal Register (78 FR 28735) amending 21 CFR 1308.11(h) to 

temporarily place these three synthetic cannabinoids into schedule I of the CSA pursuant to the 

temporary scheduling provisions of 21 U.S.C. 811(h). This Final Order, which became 

effective on the date of publication, was based on findings by the Deputy Administrator of the 

DEA that the temporary scheduling of these three synthetic cannabinoids was necessary to 

avoid an imminent hazard to the public safety pursuant to 21 U.S.C. 811(h)(1). 

As described in the May 16, 2013 Final Order, UR-144, XLR11 and AKB48 are synthetic 

cannabinoids that are pharmacologically similar to delta 9-tetrahydrocannabinol (Δ9-THC) and 

JWH-018. A review of the scientific literature finds that UR-144, XLR11, and AKB48 have no 

currently accepted medical uses and the substances are being misused and abused for their 

psychoactive properties. The Assistant Secretary of Health for the U.S. Department of Health 

and Human Services (HHS) has advised that there are no exemptions or approvals in effect for 

UR-144, XLR11, and AKB48 under section 505 (21 U.S.C. 355) of the Federal Food, Drug, and 

Cosmetic Act. As stated by the HHS, UR-144, XLR11 and AKB48 have no known accepted 

medical use. They are not the subject of any approved new drug applications (NDA) or 

investigational new drug applications (IND), and are not currently marketed as approved drug 

products. With no known industrial or medical use and no safety information, manufacturers 

are surreptitiously adulterating plant material with these synthetic cannabinoids or dissolving in 

liquids for distribution to the consumer with potentially dangerous consequences. The 

adulterated products, such as “Spice,” “K2,” and many others, are marketed under the guise of 

herbal incense products and as legal alternatives to marijuana. It has been established that these 

products are being abused for their psychoactive properties in the absence of information 

regarding their use and safety.
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Since 2009, there has been a marked increase in law enforcement encounters of various 

synthetic cannabinoids in the United States. Both law enforcement and public health reports 

suggest the sustained popularity of these substances in the designer drug market, which are most 

commonly abused as plant material adulterants. These associated products are often being sold 

as incense and labeled “not for human consumption.” Additionally, these products are 

marketed as a “legal high” or “legal alternative to marijuana” and are readily available over the 

internet, in head shops, or sold in convenience stores. 

The three substances have no currently accepted medical use in treatment in the United 

States and have been reported to produce adverse effects in humans. Chronic abuse of synthetic 

cannabinoids has been linked to adverse health effects including signs of addiction and 

withdrawal (Zimmermann et al., 2009; Muller et al., 2010), as well as numerous reports of 

emergency room admissions resulting from their abuse (Forrester et al., 2011; HermannsClausen et al., 2013; SAMHSA, 2012). The American Association of Poison Control Centers 

(AAPCC) has reported that many of the synthetic cannabinoid calls are from either emergency 

departments or placed while en route to a medical facility. 

UR-144, XLR11 and AKB48 are synthetic cannabinoids (Figure 1) and are 

pharmacologically similar to the schedule I hallucinogen delta-9-tetrahydrocannabinol (Δ9-

THC). UR-144 and XLR11 are classified as cyclopropoylindoles, while AKB48 is classified as 

an indazole-3-carboximide. UR-144 was first developed as a research tool by Abbott 

Laboratories (Frost et al., 2010). XLR11 and AKB48 were not designed as research tools;

however, these two substances were reported by law enforcement in drug seizures dating back 

to 2011. According to data from the System to Retrieve Information on Drug Evidence 

(STRIDE) and STARLiMS,

1

from January 1, 2010 through December 31, 2014, there were 

2,049 reports involving 245 cases for UR-144; 4,041 reports involving 487 cases for XLR11;

and 201 reports involving 63 cases for AKB48. From January 2010 to December 2014, the 

National Forensic Laboratory Information System (NFLIS)

2

registered 46,324 reports 

 

1

STRIDE collected the results of drug evidence analyzed at DEA laboratories and reflects evidence submitted by 

the DEA, other Federal law enforcement agencies, and some local law enforcement agencies. On October 1, 2014, 

STARLiMS replaced STRIDE as the DEA laboratory drug evidence data system of record.

2 The National Forensic Laboratory Information System (NFLIS) is a comprehensive information system that 

includes data from forensic laboratories that handle approximately 90% of an estimated 1.0 million distinct annual 

State and local drug analysis cases. NFLIS includes drug chemistry results from completed analyses only. While 

NFLIS data is not direct evidence of abuse, it can lead to an inference that a drug has been diverted and abused. 

See 76 FR 77330, 77332, Dec. 12, 2011.
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containing these synthetic cannabinoids—including 8,548 reports of UR-144; 36,837 reports of 

XLR11; and 939 reports of AKB48—across at least 43 states. No reports regarding UR-144, 

XLR11, or AKB48 were reported in NFLIS prior to March 2010. 

For the period from January 2010 through December 2014, NFLIS reports for the three 

synthetic cannabinoids UR-144, XLR11, and AKB48 (46,324 total reports) exceeded the 

number of reports for the five synthetic cannabinoids JWH-018, JWH-073, JWH-200, CP47,497, and CP-47,497 C87,743 total reports). JWH-018, JWH-200, JWH-073, CP-47,497 and 

CP-47,497 C8 homologue were temporarily scheduled on March 1, 2011, and were controlled 

as schedule I substances by Section 1152 of the Food and Drug Administration Safety and 

Innovation Act (FDASIA), Pub. L. 112-144, on July 9, 2012. Section 1152 of FDASIA 

amended the CSA by controlling cannabimimetic agents and 26 specific substances (including 

15 synthetic cannabinoids, 2 synthetic cathinones, and 9 phenethylamines of the 2C-series) as

schedule I substances. UR-144, XLR11, and AKB48 were not included among the 15 specific 

named synthetic cannabinoids, and do not fall under the definition of cannabimimetic agents 

under FDASIA. 

UR-144, XLR11, and AKB48 appeared on the designer drug market with limited to no 

pharmacological information and were being abused for their psychoactive properties. Due to 

the number of health and safety issues associated with the trafficking and abuse of these 

substances, studies were initiated. These studies further demonstrate the dangers of introducing 

a non-approved drug substance to consumers.

Numerous state public health departments and poison control centers have warned of the 

dangers associated with the misuse and abuse of synthetic cannabinoids and their associated 

products being encountered on the designer drug market. In response to the use and abuse of 

these substances, numerous states and local jurisdictions have controlled these designer drugs.

The American Association of Poison Control Centers (AAPCC) began reporting exposure calls 

corresponding to products purportedly laced with synthetic cannabinoids since 2011, although 

the data provided do not generally include biological sample testing that would confirm the 

specific type of cannabinoid. AAPCC reported 6,968 exposure calls in 2011 and 5,230 calls in 

2012. While exposure calls decreased in 2013 to 2,668, calls involving exposure to a synthetic 

cannabinoid rebounded in 2014, reaching 3,680. In addition, 623 calls have been reported from 

January 1 through February 28, 2015. A majority of these exposure incidents resulted in 
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medical attention being sought at health care facilities. Products containing at least one or more 

of the aforementioned three synthetic cannabinoids have been connected to these exposure 

incidents.

Prior to the publication of the DEA Final Order on May 16, 2013, the aforementioned 

substances and their associated products were obtainable on Internet websites and in local retail 

shops (e.g., head shops, convenient stores, and tobacco shops), and with no regard for human 

health or safety, these substance were introduced with human consumption intended. While 

mixed with green plant material, it is the laced synthetic cannabinoid that is considered to be the 

pharmacologically active component in these products (Zuba et al., 2011; Wells and Ott, 2011). 

Even with no currently accepted industrial or medical use for these substances, law 

enforcement, including Customs and Border Protection, has had numerous encounters of bulk 

quantities (often exceeding 1 kg) of synthetic cannabinoids, including UR-144, XLR11 and 

AKB48. Additionally, law enforcement officials have uncovered clandestine product 

manufacturing labs of varying sizes. Furthermore, law enforcement has encountered 

individuals abusing herbal incense products, driving under the influence of herbal incense 

products, manufacturing said products, and responding to exposure incidents that warrant 

admission of the users of these products to emergency departments. Accidental overdosing with 

complications is a public health concern. This is further exacerbated by products that are 

marketed under one retail name despite having different amounts and types of synthetic 

cannabinoid adulterated onto the plant material (Auwärter et al., 2009; Dresen et al., 2010; Zuba 

et al., 2011). Finally, the lack of information regarding product ingredients and composition

poses additional health and safety concerns for the unsuspecting user.

II. Eight Factors Determinative of Control

In accordance with the provisions of 21 U.S.C. § 811(b) of the Controlled Substances Act 

(CSA), the DEA has gathered the necessary data, including scientific, public health, and law 

enforcement information on these three substances, as well as their associated products. The 

DEA collected data in light of the information to be considered under 21 U.S.C. § 811(c). On 

August 31, 2013, the DEA requested a scientific and medical evaluation and scheduling 

recommendation from the Assistant Secretary of Health for HHS for UR-144, XLR11 and 

AKB48 pursuant to 21 U.S.C. 811(b). Upon receipt and evaluation of the scientific and medical 
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evaluation and scheduling recommendation from the Assistant Secretary, the DEA concluded its 

analysis of all other relevant data and implemented its proposal to place UR-144, XLR11 and 

AKB48 into schedule I of the CSA. 

Factor 1: The Actual or Relative Potential for Abuse

Potential for Abuse

The abuse potential of schedule I hallucinogens, such as lysergic acid diethylamide (LSD), 

psilocybin, mescaline, and JWH-018, is well documented. The abuse of these hallucinogens is 

associated with their ability to evoke hallucinogenic effects. UR-144, XLR11 and AKB48

share pharmacological properties with schedule I substances, including delta-9-

tetrahydrocannabinol (Δ

9

-THC) and JWH-018 (Weissman et al., 1982; Compton et al., 1992; 

Wiley et al., 1998; Wiley et al., 2012). Behavioral evaluations in animal models, especially 

drug discrimination studies, demonstrate that cyclopropoylindoles and indazole-3-carboximides

produce Δ

9

-THC-like discriminative stimulus effects (Wiley et al., 2013; Perkin Elmer, 2013a; 

Perkin Elmer, 2013b; Frost et al., 2010; Aung et al., 2000; Wiley et al., 2012). The drug 

discrimination study in animals is a pharmacologically selective behavioral animal model of 

“perceived” effects of psychoactive agents and highly predictive of psychoactivity in humans 

(Compton et al., 1993; Solinas et al., 2006). Additionally, Compton and colleagues (1993) 

stated that their study provided evidence that in vitro cannabinoid binding affinity is predictive 

of in vivo potency in the rat drug discrimination model. 

In addition to these studies, there are also numerous anecdotal self-reports substantiating 

that these substances and the associated products are abused by humans for their hallucinogenic 

effects, as well as published reports indicating an increase in the abuse of these substances

(Lindigkeit et al., 2009; Every-Palmer, 2011; AAPCC Press Releases). In evaluating symptoms 

upon smoking herbal incense products, Hermanns-Clausen and colleagues (2009) reported 

similarities between cases resembling severe cannabis-intoxication in an abstract to the 

International Congress of the European Association of Poison Centres and Clinical 

Toxicologists. Furthermore, the observed health effects are not anticipated based on the 

declared herbs (Auwärter et al., 2009; Lindigkeit et al., 2009; Zuba et al., 2011; Ernst et al., 

2011). 
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CB1 receptor binding studies conducted using UR-144, XLR11 and AKB48 resulted in

binding affinity (Ki) values of 28.9, 24.2, and 304.5 nM, respectively. These data demonstrate

that UR-144, XLR11, and AKB48 bind to the CB1 receptor with high affinity (Wiley et al., 

2013; Perkin Elmer, 2013a). CB1 receptor functional assays for UR-144, XLR11, and AKB48 

resulted in EC50 values of 98.1, 159, and 585 nM, respectively. These data further demonstrate 

that these compounds act as agonists of the CB1 receptor (Wiley et al., 2013; Perkin Elmer, 

2013b). In addition, UR-144, XLR11, and AKB fully substituted for the discriminative effects 

of Δ

9

-THC in the drug discrimination test (Wiley et al., 2013; NIDA study reports). 

Abuse Liability Studies in Humans

UR-144, XLR11, and AKB48 have not been evaluated in human abuse liability studies. 

Furthermore, no studies have been undertaken to evaluate the toxicology and safety of these 

substances in humans. Due to the adverse health and safety concerns associated with the abuse 

of synthetic cannabinoids, research groups have investigated and published on the detection of 

synthetic cannabinoids in specimens. A number of recent papers reported on the detection of 

the urinary metabolites for UR-144, XLR11, and AKB48 (Amaratunga et al, 2014; Mohr et al., 

2014; Scheidweiler and Huestis, 2014; Scheidweiler et al., 2015).

Actual Abuse

State public health departments and poison control centers have issued warnings in response 

to adverse health effects associated with herbal incense products containing synthetic 

cannabinoids to include tachycardia, elevated blood pressure, unconsciousness, tremors, 

seizures, vomiting, hallucinations, agitation, anxiety, pallor, numbness and tingling. Numerous 

public health and poison control centers have issued warnings regarding the abuse of synthetic 

cannabinoids and their associated products (Appendix 1). Law enforcement has encountered 

incidents of exposure, primarily in response to the smoking of products purported to be laced 

with these substances (Appendix 1). Synthetic cannabinoids have been reported in association 

with driving under the influence of drugs. Two articles published results relating to UR-144 

and one of the articles also included data on XLR11 (Louis et al., 2014; Karinen et al, 2015). 

Further, a scientific article described the effects produced by UR-144 and the associated 

impairment unsafe for driving (Adamowicz and Lechowicz, 2015). Bans on the use of these 
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synthetic cannabinoids by military personnel have been issued in response to the abuse of

synthetic cannabinoids and their related products (Bebarta et al., 2010).

Dresen and colleagues (2011) analyzed 101 serum samples from 80 subjects provided by 

different hospitals, detoxification and therapy centers, forensic psychiatry centers, and Institutes 

of Forensic Medicine. The prevalence of positive samples for synthetic cannabinoids was 

highest amongst those originating from forensic psychiatric centers, with 63.3% positive 

samples. Additionally, U.S. Drug Courts3have communicated concerns related to the abuse of 

synthetic cannabinoids. In addition, The Monitoring the Future study reported that 1 in 9 high 

school students have reported using synthetic cannabinoids (Johnston et al., 2013). 

Factor 2: Scientific Evidence of Pharmacological Effect, if Known

UR-144 and XLR11 are classified as cyclopropoylindoles, a class of compounds that have 

previously been investigated due to their possible cytotoxic, anti-cancer, or anti-HIV potentials 

(Wang et al., 1996, Milbank et al., 1999, Sharma et al., 2001, Choi and Ma, 2010, Hassam, 

2012), as well as their affinity for cannabinoid receptors (Frost et al., 2010). Currently available 

data for UR-144 include binding (Frost et al., 2010; Perkin Elmer, 2013a; Wiley et al, 2013),

locomotor (NIDA 2013e), and drug discrimination (Wiley et al., 2013; NIDA 2013j) data 

(Table 1). Similarly, currently available data for XLR11 include binding, functional, and drug 

discrimination data (Wiley et al., 2013), as well as locomotor data (NIDA 2013f; Table 1). 

AKB48 is classified as an indazole-3-carboxamide and has been reported in the literature as a 

cannabinoid agonist (Uchiyama et al., 2013; Uchiyama et al., 2012). To date, AKB48 has been 

evaluated in in vitro binding and functional assays (Perkin Elmer, 2013a; Perkin Elmer 2013b) 

and in in vivo, locomotor (2013g; see Table 1), and drug discrimination (NIDA 2013l; see Table 

1) assays.

Receptor Binding Profiles

UR-144: The CB1 receptor binding assay for UR-144 involved membrane preparations 

isolated from a HEK-293 expression system. UR-144 binds to CB1 receptor with a reported 

 

3 Drug courts were developed to achieve a reduction in recidivism and substance abuse among nonviolent, 

substance abusing offenders by increasing their likelihood for successful rehabilitation through early, continuous, 

and intense judicially supervised treatment, mandatory periodic drug testing, and the use of appropriate sanctions 

and other rehabilitation services. Drug courts analyze specimens from participants for new and existing drugs of 

abuse.
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binding affinity (Ki) of 150 nM and to the CB2 receptor with a reported binding affinity (Ki) of 

1.8 nM (Frost et al., 2010). Another study shows that UR-144 binds to the CB1 receptor with 

an apparent Ki value of 28.9 nM and to the CB2 receptor with an apparent Ki value of 4.51 nM 

(Wiley et al., 2013).

XLR11: The CB1 receptor binding assay for XLR11 involved membrane preparations 

isolated from a HEK-293 expression system. XLR11 was shown to bind to the CB1 receptor 

with an apparent Ki value of 24.2 nM and to the CB2 receptor with an apparent Ki value of 2.13 

nM (Wiley et al., 2013).

AKB48: AKB48 has been evaluated in a human CB1 receptor binding study. AKB48 was 

shown to bind to the CB1 receptor with an apparent Ki value of 304.5 nM (NIDA 2013c).

Receptor Activation

UR-144: UR-144 has been investigated via a functional assay, guanosine triphosphate 

(GTPγ[

35S]) binding assay. UR-144 stimulated GTPγ[35S]turnover through the human CB1 

receptor at nanomolar concentrations, which is indicative of compounds that can act as agonists 

at G protein-coupled receptor sites. UR-144 is an agonist at the CB1 receptor with a reported 

EC50 of 98.1 nM and an agonist at the CB2 receptor with a reported EC50 of 334 nM (Wiley et 

al., 2013). 

XLR11: XLR11 has been investigated via a functional assay, GTPγ [

35S] binding assay. 

XLR11 stimulated GTP-γ35S turnover through the human CB1 receptor at nanomolar 

concentrations, which is indicative of compounds that can act as agonists at G protein-coupled 

receptor sites. XLR11 is an agonist at the CB1 receptor with a reported EC50 of 159 nM and an 

agonist at the CB2 receptor with a reported EC50 of 145 nM (Wiley et al., 2013).

AKB48: AKB48 has been investigated via a functional assay. A functional CB1 (human) 

assay was performed using CHO cells that expressed the human CB1 receptor. AKB48 is an 

agonist at the CB1 receptor with a reported EC50 of 585 nM (NIDA 2013c).

Animal Studies – Drug Discrimination

A cannabinoid drug discrimination study is an accepted animal model for predicting 

subjective effects in humans (Balster and Prescott, 1992). 
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UR-144: UR-144 substituted fully (median effective dose, ED50 = 7.1 μmol/kg, 30 minutes 

before testing) for the discriminative stimulus effects of THC in mice trained to discriminate 5.6 

mg/kg of THC from vehicle control. Full substitution occurred at a dose (5.6 mg/kg) that did not 

alter response rate (Wiley et al., 2013). 

XLR11: XLR11 substituted fully (ED50 = 3.3 μmol/kg, 30 minutes before testing) for the 

discriminative stimulus effects of THC in mice trained to discriminate 5.6 mg/kg of THC from 

vehicle control. Full substitution occurred at a dose (3 mg/kg) that did not alter response rate 

(Wiley et al., 2013).

AKB48: XLR11 substituted fully (ED50 = 0.23 mg/kg, 30 minutes before testing) for the 

discriminative stimulus effects of THC in mice trained to discriminate 3.0 mg/kg of THC from 

vehicle control. (NIDA, 2013l).

Animal Studies – Locomotor Effects

UR-144: Treatment with UR-144 resulted in time- and dose-dependent depression of 

locomotor activity following 10 and 30 mg/kg (NIDA 2013e). Depressant effects of 10 and 30 

mg/kg occurred within 10 minutes following injection and lasted 60 to 90 minutes. An ID50 of 

7.8 mg/kg was estimated based on a 30-minute time period in which maximal depressant effects 

occurred (10 to 40 minutes following injection).

XLR11: Treatment with XLR11 resulted in time- and dose-dependent depression of 

locomotor activity following 10 and 30 mg/kg (NIDA 2013f). Depressant effects of 10 and 30 

mg/kg occurred within 10 minutes following injection and lasted 40 to 60 minutes. An ID50 of 

10.3 mg/kg was estimated based on a 30-minute time period in which maximal depressant 

effects occurred (10 to 40 minutes following injection).

AKB48: Treatment with AKB48 resulted in time- and dose-dependent depression of 

locomotor activity following 3 to 30 mg/kg (NIDA 2013g). Depressant effects of 3 mg/kg 

occurred within 20 minutes following injection and lasted 70 minutes. An ID50 of 2.2 mg/kg 

was estimated based on a 30-minute time period in which maximal depressant effects occurred 

(10 to 40 minutes following injection).

Animal Studies – Tetrad Test

The mouse tetrad is a well-established paradigm for evaluating substances for 

cannabimimetic properties (Martin et al., 1991). Each mouse is tested in a battery of four tests, 
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in which cannabinoid agonists have been previously shown to produce a characteristic profile of 

in vivo effects including: 1) suppression of locomotor activity, 2) antinociception in the warm 

water tail withdrawal assay, 3) decreased rectal temperature and 4) ring immobility. UR-144 

and XLR11 have been evaluated in all four parameters of the mouse tetrad (Wiley et al., 2013).

Δ

9

-THC (positive control), and they exhibited the complete profile of cannabinoid effects in the 

tetrad tests in mice, with each compound producing dose-dependent suppression of spontaneous 

activity, antinociception, hypothermia and ring immobility. ED50 values are listed in Table 1. 

With the exception of the effect of UR-144 on spontaneous activity, one or more doses of each 

compound significantly affected each measure (p<0.05, compared to vehicle/negative control). 

UR-144 showed a trend towards decreased activity; however the effect did not reach statistical 

significance. AKB48 was not evaluated using the mouse tetrad test. 

Table 1. Potencies of compounds in the tetrad test for Δ9-THC, UR-144 and XLR11A

Compound Spontaneous 

Activity

Hot Water Tail 

Immersion Test

Rectal 

Temperature

Ring Immobility

Δ

9

-THC 15 12 4 3

UR-144 1 2.6 0.6 1

XLR11 0.9 3.3 0.6 0.6

A Values represent ED50 in μmol/kg. (Wiley et al., 2013)
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Table 2. Summary of Available Pharmacology Data for UR-144, XLR11, and AKB48

In vitro In vivo

Binding at 

CB1 Function at CB1

Locomotor 

Activity

(8-hr session)

THC Drug 

Discrimination 

UR-144 Ki = 28.9 nMH

Ki = 150 nMM

Ki = 29 nMN

Agonist

EC50 = 98 nMN

Agonist

EC50 = 1295

nMA

Depressed

ID50=7.8 mg/kgE

Full Substitution

ED50 = 7.1 

μmol/kgN

Full Substitution

ED50 = 0.44 mg/kgJ

XLR11 Ki = 24.2 nMI

Ki = 24 nMN

Agonist

EC50 = 159 nMN

Agonist

EC50 = 98.1 

nMB

Depressed

ID50=10.3 mg/kgF

Full Substitution

ED50 = 3.3 

μmol/kgN

Full Substitution

ED50 = 0.16 mg/kgK

AKB48 Ki = 304.5 

nMC

Agonist

EC50 = 585 nMD

Depressed

ID50=2.2 mg/kgG

Full Substitution

ED50 = 0.23 mg/kgL

A NIDA, 2013a

B NIDA, 2013b

C NIDA, 2013c

D NIDA, 2013d

E NIDA, 2013e

F NIDA, 2013f

G NIDA, 2013g

H NIDA, 2013h

I NIDA, 2013i

J NIDA, 2013j

K NIDA, 2013k

L NIDA, 2013l

M

(Frost et al., 2010)

N

(Wiley et al., 2013)

Human Studies

No human clinical studies involving UR-144, XLR11, or AKB48 have been reported. 

Factor 3: The State of Current Scientific Knowledge Regarding UR-144, XLR11, and 

AKB48

Synthetic cannabinoids emerged in the early 1980s. They were originally designed to 

investigate structure activity relationships (SAR) based on the potent substance, 9-nor-9βhydroxyhexahydrocannabinol (HHC) (Weissman et al., 1982; Melvin et al., 1984). Interest in 
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various structural classes was generated by the mouse vas deferens (MVD) and prostaglandin 

synthetase activity of pravadoline and subsequent finding of affinity to the cannabinoid receptor

(Huffman, 2009). 

The emergence of synthetic cannabinoids in the designer drug market can be traced to the 

initial forensic laboratory confirmation in mid-December 2008. A commercial laboratory in 

Frankfurt, Germany announced the identification of JWH-018 in samples of herbal incense, and 

others were identified shortly after this initial determination (Piggee, 2009). UR-144 and 

XLR11 are classified as cyclopropoylindoles, whereas AKB48 is classified as an indazole-3-

carboximide. While UR-144 was first developed as a research tool by Abbott Laboratories 

(Frost et al., 2010), XLR11 and AKB48 were not designed for use in the laboratory and began 

showing up in seizures in 2011. 
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Chemistry and Physical Properties

N

N

NH

O

AKB-48

N

O

UR-144

N

O

XLR-11

F

Figure 1. Chemical Structures of UR-144, XLR11, and AKB48

Table 3. The chemical and physical properties of 1-pentyl-3-(2,2,3,3-

tetramethylcyclopropoyl)indole

1-pentyl-3-(2,2,3,3-

tetramethylcyclopropoyl)indole

CAS # 1199943-44-6

Chemical Formula C21H29NO

Molecular Weight 311.5

Synonyms UR-144

Systemic Name (IUPAC, CAS) (1-pentyl-1H-indol-3-yl)(2,2,3,3-

tetramethylcyclopropyl)methanone

Table 4. The chemical and physical properties of 1-(5-fluoro-pentyl)-3-(2,2,3,3-

tetramethylcyclopropoyl)indole

1-(5-fluoro-pentyl)-3-(2,2,3,3-

tetramethylcyclopropoyl)indole

CAS # 1364933-54-9

Chemical Formula C21H28FNO

Molecular Weight 329.5

Synonyms XLR11, XLR-11, 5-fluoro-UR-144, 5-FUR-144

Systemic Name (IUPAC, CAS) [1-(5-fluoro-pentyl)-1H-indol-3-

yl](2,2,3,3-

tetramethylcyclopropyl)methanone
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Table 5. The chemical and physical properties of N-(1-adamantyl)-1-pentyl-1H-indazole-3-

carboxamide

N-(1-adamantyl)-1-pentyl-1H-indazole3-carboxamide

CAS # 1345973-53-6

Chemical Formula C23H31N3O

Molecular Weight 365.5

Synonyms AKB48, APINACA

Systemic Name (IUPAC, CAS) N-(1-adamantyl)-1-pentyl-1H-indazole-3-

carboxamide

Laboratory analyses of numerous herbal incense products have been conducted and results 

have been published in the scientific literature detailing the identification of these synthetic 

cannabinoids in products and the variations in the amount of the substance spiked on the plant 

material in products sold through retail channels (Auwärter et al., 2009; EMCDDA, 2009;

Dresen et al., 2010; Uchiyama et al., 2010; Hudson et al., 2010; Zuba et al., 2011; Uchiyama et 

al., 2013; Langer et al., 2013; Kavanagh et al., 2013).

Metabolism and Pharmacokinetics

Sobolesvsky et al. (2012) analyzed the metabolites of UR-144 both in vitro and from human 

urine samples. Results demonstrated a high level of correlation between the in vitro and in vivo

results with, with three out of the five metabolites detected in urine samples. It was noted that 

UR-144 almost completely metabolizes in vivo, and it was suggested that both the mono- and 

dihydroxy metabolites of UR-144 should be detectable at least one week following 

administration (Sobolevsky et al., 2012). Grigoryev et al. (2013) described the detection of 16 

metabolites of UR-144 and 21 metabolites of the major UR-144 pyrolysis products obtained 

from urine samples as shown via LC-MS (liquid chromatography – mas spectroscopy) and GCMS (gas chromatography-mass spectroscopy). Compounds containing hydroxyl groups on the 

aliphatic moieties were identified as the most abundant metabolites (Grigoryev et al., 2013). 

Wohlfarth et al. (2013) reported that XLR-11 underwent phase I and II metabolism, producing 

more than 25 metabolites resulting from hydroxylation, carboxylation, hemiketal, and 

hemiacetal formation, internal dehydration, and further glucuronidation of some oxidative 

metabolites. XLR11 was shown to be deflourinated, thus producing UR-144 metabolites as 

well. Based on results from mass spectrometry, Wohlfarth et al. (2013) reported major 
16

metabolites of XLR11 that included 2-carboxy-XLR-11, UR-144 pentanoic acid, 5-hydroxyUR-144, hydroxy-XLR-11 glucuronides, and 2-carboxy-UR-144 pentanoic acid. 

Medical Application

The DEA is not aware of any currently accepted medical use or New Drug Applications 

(NDA) for UR-144, XLR11, or AKB48. A letter dated February 14, 2013 was sent from DEA 

Deputy Administrator to Assistant Secretary for Health, Department for Health and Human 

Services as notification of intent to temporarily place these three substances in schedule I and 

solicited comments, including whether there is an exemption or approval was in effect for the 

substances in question under the Federal Food, Drug and Cosmetic Act. The Assistant 

Secretary of Health responded that there were no current INDs or NDAs for these synthetic 

cannabinoids in a letter to the DEA Assistant Administrator dated March 14, 2013. In their 

scheduling recommendation, the HHS reiterated that UR-144, XLR11, and AKB48 have no 

known accepted medical use, are not the subject of any approved new drug applications (NDA) 

or investigational new drug applications (IND), and are not currently marketed as any approved 

drug products. 

Factor 4: History and Current Pattern of Abuse

Synthetic cannabinoids were first reported in the United States in a December 2008 

encounter, where a shipment of “Spice” was seized and analyzed by U.S. Customs and Border 

Patrol in Dayton, Ohio. Additionally around the same time, in December 2008, JWH-018 and 

cannabicyclohexanol were identified by German forensic laboratories (EMCDDA, 2009). 

Though these substances were not identified until 2008, these substances likely existed and 

were abused some time prior to their identification (Psychonaut Web Mapping Research Group, 

2009).

Since the initial identification of JWH-018 (December 2008), many additional synthetic 

cannabinoids have been found laced on related products (Auwarter et al., 2009; DEA, 2009). 

The popularity of these cannabimimetic substances and their associated products appears to 

have increased since January 2010 in the United States based on seizure exhibits and media 

reports. This trend appears to mirror those experienced in Europe since 2008 (EMCDDA, 

2009). Synthetic cannabinoids are being encountered in most regions of the U.S. with the 
17

substances found as adulterants on plant material or being abused alone as self-reported on 

internet discussion boards (Atwood et al., 2010). 

Data gathered from published studies, supplemented by discussions on Internet discussion 

websites and personal communications demonstrate that these products are being abused mainly 

by smoking for their psychoactive properties. The adulterated products are marketed as “legal”

alternatives to marijuana. It is believed this characterization and their reputation as potent 

herbal intoxicants has contributed to their increased their popularity (Lindigkeit et al., 2009). 

These substances alone or laced on plant material have the potential to be extremely harmful to 

the user due to their method of manufacture and the potency of the substances. Several 

synthetic cannabinoids have been shown to display higher potency in vitro and in vivo when 

compared to Δ9-THC (Compton et al., 1992a; Wiley et al., 1998). Smoking mixtures of these 

substances abused for the purpose of achieving intoxication have resulted in numerous 

emergency room visits and calls to poison control centers. Numerous states, local jurisdictions, 

and the international community have also controlled these substances.

Synthetic cannabinoids have been developed over the last 30 years to be used as tools for 

investigating the cannabinoid system (Weissman et al., 1982; Huffman et al., 1996; Huffman et 

al., 1999). Subsequently, these substances have been identified as adulterants in numerous 

retail products (Auwarter et al., 2009; EMCDDA, 2009; Lindigkeit et al., 2009; Dresen et al., 

2010; Hudson et al., 2010; Uchiyama et al., 2010; Uchiyama, 2012; Uchiyama et al., 2013; 

Kavanagh et al., 2013). JWH-018 was the first synthetic cannabinoid to be identified as a 

product adulterant in Germany in 2008. This substance was initially synthesized as a research 

tool to investigate the cannabinoid system (Huffman et al., 1994; Wiley et al., 1998). Since 

then, numerous other synthetic cannabinoids including UR-144, XLR11 and AKB48 have been 

identified as product adulterants and bulk seizures have occurred by law enforcement. NFLIS 

details over 48,324 reports from forensic laboratories identifying UR-144, XLR11 and AKB48 

in drug related reports for a period from January 2010 to December 2014. In addition, STRIDE 

and STARLiMS have 6,271 reports involving UR-144, XLR11 and AKB48 from January 1, 

2010 through December 31, 2014.

Youth appear to be the primary abusers of synthetic cannabinoids and synthetic 

cannabinoid-containing products, as supported by law enforcement encounters and reports from
18

emergency rooms (SAMHSA, 2012)4; however, all age groups have been discussed in media 

reports as abusing these substances and related products. In 2010, an estimated 11,406 

emergency department (ED) visits involved a synthetic cannabinoid product. For patients 

between the ages of 12-29, 75% of emergency department visits in 2010 involved synthetic 

cannabinoids. In 2011, the estimated ED visits involving a synthetic cannabiniod increased 

significantly to an estimated 28,531 visits (SAMHSA, 2014). Synthetic cannabinoids were 

involved in 79% of ED patients between the ages of 12 and 29 in 2011. In addition, the 

majority (65%) of emergency department visits of patients aged 20 and younger, which 

involved SCs, did not involve any other substance. Of the remaining 35% of these individuals,

the most frequently abused substances in combination with SCs were marijuana (17%), 

pharmaceuticals (16%) and alcohol (15%) (SAMHSA, 2014). Individuals, including minors,

are purchasing synthetic cannabinoids from Internet websites, gas stations, convenience stores, 

and head shops. These substances and products laced with synthetic cannabinoids are 

commonly marketed as “legal highs” with a disclaimer of “not for human consumption.” As 

detailed in reports, law enforcement and public health officials are encountering the abuse of 

these substances and their associated products (CDC, 2013; NFLIS, 2013; STRIDE, 2013, 

STARLiMS, 2014).

Numerous “herbal incense” products have been found to contain one or more synthetic 

cannabinoid(s) (ex. UR-144, XLR11 and/or AKB48) laced on plant material (Appendix 1). 

There is no known explanation for the addition of these synthetic cannabinoids to plant material 

being marketed as herbal incense, other than for their psychoactive properties (Lindigkeit et al., 

2009). The psychoactive properties are directly linked to the synthetic cannabinoids laced on 

the plant material sold as retail products (Auwarter et al., 2009; EMCDDA, 2009, Atwood et al., 

2010). To lace the plant material, the synthetic cannabinoids are generally dissolved in a 

solvent and sprayed on the plant material or the plant material is soaked in a solution of the 

dissolved substance (Vardakou et al., 2010; Wells and Ott, 2011). Two research articles 

propose that the packaging is professional and inconspicuous (unlabeled), targeting young 

people who are eager to use cannabis but are afraid of the judicial consequences and its

association with illicit drugs (Lindigkeit et al., 2009: Schifano, 2009).

 

4

SAMHSA is a branch of the U.S. Department of Health and Human Services. It is charged with improving the 

quality and availability of prevention, treatment, and rehabilitative services in order to reduce illness, death, 

disability, and cost to society resulting from substance abuse and mental illnesses.
19

Dresen and colleagues (2010) found that synthetic cannabinoids are being abused by 

individuals in drug treatment centers with a positive rate of 63.3% in forensic psychiatric 

centers based on their sampling. U.S. Drug Courts have communicated concerns related to the 

abuse of synthetic cannabinoids and a response rate of greater than 30% by juveniles subject to 

routine drug screens from a sampling.

As part of the Monitoring the Future (MTF)5 Report for 2012, some of the most important 

findings were presented in a press release on December 19, 2012. In this press release, the MTF 

study detailed that while synthetic cannabinoid use has remained level in 12th graders at 11.3%, 

“the fact that its prevalence rate has remained high despite federal and state efforts to reduce its 

use is troublesome” (Johnston et al., 2013). For the first time, synthetic cannabinoid use in 8th 

and 10th graders was measured, with annual prevalence rates being 4.4% and 8.8% respectively.

In the most recent report from MTF (2014), annual prevalence for synthetic cannabinoid use 

was 3.3% for 8th graders, 5.4% for 10th graders, and 5.8% for 12th graders (Johnston et al., 

2014).

Summary

Recently, law enforcement has encountered UR-144, XLR11, and AKB48 and their 

products in increasing numbers. Synthetic cannabinoids and their associated products are 

available over the Internet, in gas stations, convenience stores, and tobacco and head shops. 

UR-144, XLR11 and AKB48, similar to the previously scheduled synthetic cannabinoids (DEA, 

2012), have been seized alone and spiked on products that are marketed as herbal incense and 

promoted as legal alternatives to marijuana. The misuse and abuse of these substances and their 

associated products is a significant problem for public health and safety. 

Factor 5: The Scope, Duration, and Significance of Abuse

As stated by the HHS, based on their pharmacological properties, it is reasonable to assume 

that, if uncontrolled, the scope, duration, and significance of UR-144, XLR11, and AKB48 

abuse could be similar to marijuana. NFLIS, a national database capturing data from forensic 

laboratories, has reported 46,324 reports (January 2010 to December 2014) related to UR-144, 

 

5 MTF is a national survey conducted by the Institute for Social Research at the University of Michigan under a 

grant from the National Institute on Drug Abuse (NIDA) that tracks drug use trends among American adolescents 

in the 8th, 10th, and 12th grades.
20

XLR11 and AKB48 from 44 states (Table 10) (query date: April 30, 2015). STRIDE and 

STARLiMS have 6,271 reports involving UR-144, XLR11 and/or AKB48 from January 1, 2010 

through December 31, 2014. Recently, increased exposure incidents have been documented by 

poison control centers in the United States as the abuse of synthetic cannabinoids has been 

associated with both acute and long-term public health and safety concerns. The American 

Association of Poison Control Centers (AAPCC) has reported exposure calls corresponding to 

products purportedly laced with synthetic cannabinoids since 2011, although the data provided 

does not generally include biological sample testing that would confirm the specific 

cannabinoid. AAPCC reported 6,968 exposure calls in 2011 and 5,230 calls in 2012. While 

exposure calls decreased in 2013 to 2,668, calls involving exposure to a synthetic cannabinoid 

rebounded in 2014 reaching 3,680. In addition, 623 calls have been reported from January 1 

through February 28, 2015.6 A majority of exposure incidents resulted in seeking medical 

attention at health care facilities. Chronic abuse of synthetic cannabinoids has been linked to 

signs of addiction and withdrawal similar to that experienced with cannabis abuse 

(Zimmermann et al., 2009, Muller et al., 2010, Vardakou et al., 2010). Additionally, tolerance 

to these drugs may develop fairly rapidly with larger doses being required to achieve the desired 

effect (EMCDDA, 2009). In 2010, the Substance Abuse and Mental Health Services 

Administration (SAMHSA) reported 11,406 emergency department visits involving a synthetic 

cannabinoid product. In 2011, SAMHSA reported the number of emergency department visits 

involving a synthetic cannabinoid product had increased 2.5 times to 28,531 (SAMHSA, 2013) 

(Figure 2).

Synthetic cannabinoids and their associated products are sold over the Internet and found to 

be abused by diverse populations. Since synthetic cannabinoids were never intended for human 

consumption, minimal information exists as to the short and long term health implications 

resulting from exposure to these substances (Griffiths et al., 2010; Vardakou et al., 2010). The 

 

6 The content of this report does not necessarily reflect the opinions or conclusions of the American Association of 

Poison Control Centers. The American Association of Poison Control centers (AAPCC; http://www.aapcc.org) 

maintains the national database of information logged by the country’s 57 Poison Control Centers (PCCs). Case 

records in this database are from self-reported calls: they reflect only information provided when the public or 

healthcare professionals report an actual or potential exposure to a substance (e.g. an ingestion, inhalation, or 

topical exposure, etc.), or request information/educational materials. Exposures do not necessarily represent a 

poisoning or overdose. The AAPCC is not able to completely verify the accuracy of every report made to member 

centers. Additional exposures may go unreported to PCCs and data referenced from the AAPCC should not be 

construed to represent the complete incidence of national exposures to any substance(s).
21

scientific literature and reports reviewed by the DEA suggest that tolerance and dependence to 

synthetic cannabinoids may develop (Zimmermann et al., 2009). 

The increased abuse of these synthetic cannabinoids in the United States is supported by an 

increasing number of encounters by law enforcement. Over the past year, in the United States, 

there has been a significant increase in availability, trafficking and abuse of UR-144, XLR11,

and AKB48, evident from the increasing number of encounters reported by forensic laboratories 

(NFLIS data). The initial indication of the evidence of abuse of AKB48 appeared in 2011 upon 

identification in products, with evidence of abuse of UR-144 and XLR11 appearing in 2012. A

previous temporary scheduling action of five synthetic cannabinoids (JWH-018, JWH-200, 

JWH-073, CP-47,497 and CP-47,497 C8 homologue [cannabicyclohexanol], March 1, 2011), 

followed by the FDAISA (Food and Drug Administration Safety and Innovation Act) (July 9, 

2012) permanently placed these initial five substances into schedule I. Manufacturers and users 

of synthetic cannabinoids then turned to new synthetic cannabinoids, namely UR-144, XLR11 

and AKB48. 

Figure 2. Emergency department visits involving synthetic cannabinoids (SAMHSA, 2013). 

Data were not collected prior to 2010.

*Estimates of ED visits are based on a representative sample of non-Federal, general, short-stay hospitals with 24-

hour EDs in the U.S.

11,406

28,531

0

5,000

10,000

15,000

20,000

25,000

30,000

2010 2011

Number of ED Visits

Emergency Department Visits Involving 

Synthetic Cannabinoids*
22

Product analyses have yielded important information regarding these synthetic substances

(Seely et al., 2013). Smoking mixtures sold in Russia have been analyzed and found to contain 

UR-144 along with other compounds, including JWH-018 (Sobolevsky et al., 2012). AKB48, 

UR-144 and XLR11 have also been identified in designer drugs currently being sold in Japan 

(Uchiyama et al., 2013; Uchiyama et al., 2012). The chronic abuse of products laced with 

synthetic cannabinoids has been linked to addiction and withdrawal (Vardakou et al., 2010).

Summary

The abuse of synthetic cannabinoids is characterized in the scientific literature and by law 

enforcement encounters with reported adverse health effects. Numerous calls have been 

received by poison control centers regarding the abuse of products potentially laced with 

synthetic cannabinoids that have resulted in visits to emergency departments. Following the 

passage of FDAISA in July of 2012, new generations of synthetic cannabinoids including UR144, XLR11 and AKB48 increasingly replaced those cannabinoids that were placed into 

schedule I of the CSA.

Factor 6: What, If Any, Risk There is to the Public Health

Law enforcement, military, and public health officials have reported exposure incidents that 

demonstrate the dangers associated with the misuse and abuse of synthetic cannabinoids to both 

the individual abusers and other affected individuals since these substances were never intended 

for human use. Warnings regarding the dangers associated with abuse of synthetic 

cannabinoids and their products have been issued by numerous state public health departments,

poison control centers, and private organizations. Detailed product analyses describe variations 

in the amount and specific synthetic cannabinoid laced on the plant material even within 

samplings of the same product (Hudson et al., 2010). These unknowns present a significant risk 

of danger to the abusing individuals (Auwarter et al., 2009, Hudson et al., 2010). Wells and Ott 

(2011) expressed concern regarding the possibility of serotonin syndrome related to synthetic 

cannabinoids of the indole structural class due to the similarity to serotonin. Some of the 

common clinical effects reported in emergency rooms in response to the abuse of synthetic 

cannabinoids include vomiting, anxiety, agitation, irritability, seizures, hallucinations, 

tachycardia, elevated blood pressure, and loss of consciousness (Harris and Brown, 2013; 

Hermanns-Clausen et al., 2013; Forrester et al., 2011; Cohen et al., 2012) (see reports from state 
23

health departments and poison control centers including AAPCC, Appendix 1). In addition, 

Mushoff et al. (2013) detailed various driving under the influence case reports where users 

operated a motor vehicle while intoxicated with synthetic cannabinoids, including UR-144. 

By sharing pharmacological similarities with certain schedule I substances (Δ9-THC and 

JWH-018), synthetic cannabinoids pose a risk to the abuser (Weissman et al., 1982, Compton et 

al., 1992a, Wiley et al., 1998), and the chronic abuse of products laced with synthetic 

cannabinoids has been linked to addiction and withdrawal (Vardakou et al., 2010). Submissions 

to DEA laboratories from January 2012 through April 03, 2013 have documented over 150 

distinct packaging examples containing mixtures of UR-144, XLR11, and/or AKB48. Similar 

products have been found to vary in the amount and type of synthetic cannabinoid laced on the 

plant material, which could be one explanation for the numerous emergency department 

admissions that have been connected to synthetic cannabinoids in general (Vearrier and 

Osterhoudt, 2010; Schneir et al., 2011). In 2010, 11,406 emergency department visits involved 

a synthetic cannabinoid product (SAMHSA, 2012). In 2011, SAMHSA reported the number of 

emergency department visits involving a synthetic cannabinoid product had increased 2.5 times

those reported in 2010 to 28,531 (SAMHSA, 2013). Health warnings have been issued by 

numerous state public health departments and poison control centers describing adverse health 

effects associated with smoking (inhaling) these products, including agitation, vomiting, 

tachycardia, elevated blood pressure, seizures, hallucinations and non-responsiveness 

(Appendix 1). 

Due to increasing trends in this newer generation of synthetic cannabinoids, UR-144 and 

XLR11 have been added to the toxicological panel (i.e. a list of synthetic cannabinoids 

commonly tested for) from two major laboratories. NMS Laboratories (Willow Grove, PA) reanalyzed 46 blood samples collected in July 2012. These samples initially tested positive for a 

synthetic drug compound, but they were not specifically tested for UR-144 or XLR11 at that 

time. Upon re-analysis, 27/46 (58%) were positive for UR-144 and 14/46 (30%) were positive 

for XLR11.

7 An additional 28 samples that were collected in December 2012 were analyzed 

using NMS Laboratories new scope which includes UR-144 and XLR11 testing. Results from 

these 28 samples demonstrated 8/28 (28%) positivity for UR-144 and 12/28 (44%) positivity for 

 

7 Correspondence from NMS Laboratories to DEA 12/31/2012
24

XLR11.

8

 Redwood Laboratories (Santa Rosa, CA) has also recently added UR-144 and XLR11 

to their toxicological panel. From January through June 2012, Redwood Laboratories reported 

between 6.5 – 9.7% positivity for synthetic cannabinoids, not including UR-144 or XLR11.

9

 

These levels diminished in the subsequent 6 months between July and December 2012, falling 

from 8.0 % in July 2012 to a low of 2.8% positivity in December 2012. Using a new panel, 

Redwood Laboratories re-analyzed 300 randomly chosen samples from December 2012, and 

found the positivity results climb to 16% (39/300 for UR-144 and/or XLR11 alone) for all 

synthetic cannabinoids tested when including UR-144 and XLR11 in the panel where tests 

without UR-144 and XLR11 showed only 2.8 % positivity (Table 5).

10

 These data suggest 

newer non-controlled synthetic cannabinoids are being abused, specifically UR-144 and 

XLR11. A third company, Premier Integrity Solutions (Russell Springs, KY), supplies the 

toxicological services for the state of Kentucky’s drug court program. Data provided by the 

court coordinator for the state of Kentucky demonstrated that there were 310 drug tests for 

synthetic cannabinoids dating from July 1, 2012, through December 20, 2012. Of these 310 

drug tests, 24 were positive for synthetic cannabinoids, with 19/24 showing positivity for UR144 or one of its metabolites.

11,12

 No testing for XLR11 or AKB48 was reported.

Table 6. Synthetic Cannabinoid Testing by Redwood Laboratories

Percent Positivity

Synthetic Cannabinoidsa

(Excluding UR-144/XLR11)

Synthetic Cannabinoidsb

(Including UR-144/XLR11)

December 2012 2.8 % 16 %

a

238/8118 total blood samples tested by Redwood Laboratories in December 2012

b

39/300 randomly selected blood samples by Redwood Laboratories from December 2012

Since abusers obtain these drugs through unknown sources, purity of these drugs is 

uncertain, thus posing significant adverse health risk to these users (EMCDDA, 2009; Dresen et 

al., 2010). As mentioned above, there are reported instances of emergency department 

admissions in association with the abuse of these THC-like substances. There is no currently 

accepted medical use of these substances in the United States.

 

8 Correspondence from NMS Laboratories to the DEA on 12/20/2012.

9 Correspondence from Redwood Laboratories to the DEA on 01/07/2013.

10 Correspondence from Redwood Laboratories to the DEA on 01/07/2013.

11 Correspondence from Kentucky Court System to the DEA on 12/20/2012.

12 Correspondence from Kentucky Court System to the DEA on 12/21/2012.
25

At least one death has been reported in Minnesota following ingestion of UR-144 and 

XLR11.

13 One death has been reported following the ingestion of AKB48.14 In 2013 in 

California, a 27-year-old female developed hypertension, tachycardia and rhabdomyolisis prior 

to being intubated and admitted to the ICU for protection of the airway following ingestion of a 

synthetic cannabinoid product containing XLR11.

15 A 33-year-old man developed acute 

cerebral ischemia and infarction shortly following the use of XLR11 (Takematsu et al., 2014). 

In addition, reports have detailed various driving under the influence cases where users operated 

a motor vehicle while intoxicated with synthetic cannabinoids, including UR-144, XLR11,

and/or AKB48 (Louis et al., 2014; Karinen et al., 2015).

In a recent publication describing various adverse effects from synthetic cannabinoids, 

numerous cases are presented involving UR-144 and/or XLR11 (Gurney et al., 2014). Adverse 

effects reported included nausea, vomiting, flank and abdominal pain, mild agitation, panic 

attacks, involuntary muscle twitching, confusion, somnolence, dilated pupils, increased heart 

rate, low potassium in blood, mild increase in blood glucose and acute kidney injury (Gurney et 

al., 2014).

In February 2013, the Centers for Disease Control (CDC) reported on an association 

between XLR11 exposure and acute kidney injury (CDC, 2013). The CDC examined 16 

patients with acute kidney injury who reported recent smoking of synthetic cannabinoids. 

Seven of the 16 patients smoked substances that were positive for XLR11 or its metabolite. In 

addition, one of these seven cases also tested positive for UR-144 (Thornton et al., 2013). A 

case series describing nine patients with acute kidney injury following ingesting of XLR11 was 

reported from the Oregon and southwestern Washington state area from May-October, 2012 

(Buser et al., 2014).

Additional case reports reported adverse health effects including nausea, vomiting, 

agitation, panic attacks, involuntary muscle twitching and confusion following ingestion of UR144 and/or XLR11. According to a letter from Assistant Secretary of Health, Department of 

Health and Human Services (dated March 14, 2013, see attached), the Food and Drug 

Administration has reported there are currently no approved drug applications and no 

investigational new drug applications for UR-144, XLR11 or AKB48. 

 

13 Correspondence from Midwest Medical Examiner’s Office, Ramsey, MN to DEA 03/19/2015

14 Correspondence from Armed Forces Medical Examiner, Department of Defense to DEA 05/01/2015

15 Correspondence from FDA to DEA 05/12/2014
26

Factor 7: Psychic or Physiological Dependence Liability

Chronic abuse of synthetic cannabinoids has been linked to signs of addiction and 

withdrawal. According to the HHS, the pharmacologic profiles of UR-144, XLR11, and 

AKB48 strongly suggest that they possess a physiological and psychological dependence 

liability that is similar to that of delta-9 (∆9) – tetrahydrocannabinol (schedule I) and JWH-018 

(schedule I). Additionally, tolerance to these drugs may develop fairly rapidly with larger doses 

being required to achieve the desired effect. While UR-144 and XLR11 are structurally and 

pharmacologically related to JWH-018, there are no studies or case reports that document the 

psychic or physiological dependence potential of UR-144, XLR11, or AKB48. 

Every-Palmer (2010) has reported of the recurrence of psychosis in stable individuals with a

previous history. Every-Palmer (2011) followed-up the initial communication with interviews 

of 15 patients with severe mental illness in a New Zealand forensic and rehabilitation service. 

In a case report, dependence syndrome corresponding to the ICD-10 and DSM-IV criteria and 

the physical withdrawal resembled cannabis dependence (Zimmermann et al., 2010) after the 

consumption of “Spice Gold.” Spice Gold has been found to contain the substance JWH-018. 

Factor 8: Whether UR-144, XLR11, and AKB48 are Immediate Precursors of a 

Substance Already Controlled

UR-144, XLR11, and AKB48 are not considered an immediate precursor of any controlled 

substance of the CSA as defined by Title 21, U.S.C § 802(23).

III. Findings for Schedule Placement Pursuant to 21 U.S.C. 812(b)

21 U.S.C. 812(b) requires the evaluation of a substance’s abuse potential, accepted medical 

use, and safety for use under medical supervision for scheduling under the CSA as a controlled 

substance. After consideration of the above eight factors determinative of control of a substance 

(21 U.S.C. 811(c)), and a review of the scientific and medical evaluation and scheduling 

recommendation provided by the HHS, the DEA finds that UR-144, XLR11, and AKB48 meet 

the following criteria for placement in Schedule I of the CSA pursuant to 21 U.S.C. 812 (b)(1).
27

1) UR-144, XLR11, and AKB48 have a high potential for abuse.

UR-144, XLR11 and AKB48 are synthetic substances that produce cannabinoid-like effects. 

The pharmacological similarity of UR-144, XLR11, and AKB48 to ∆9-THC makes it 

reasonable to assume that their potential for abuse is high and would be similar to that of JWH018, which is controlled in schedule I of the CSA. NFLIS details over 48,324 reports from 

forensic laboratories identifying UR-144, XLR11, and AKB48 for a period from January 2010 

to December 2014. In addition, STRIDE and STARLiMS have 6,271 reports involving UR144, XLR11 and AKB48 from January 1, 2010 through December 31, 2014.

2) UR-144, XLR11 and ABK48 have no currently accepted medical use in treatment in 

the United States.

According to the HHS, there are no approved NDAs for UR-144, XLR11, or AKB48 in the 

United States. There is no known therapeutic application for UR-144, XLR11, or AKB48. 

Therefore, UR-144, XLR11, and AKB48 have no currently accepted medical use in the United 

States.

3) There is a lack of accepted safety for use of UR-144, XLR11 and AKB48 under medical 

supervision.

Since UR-144, XLR11, and AKB48 have no approved medical use and have not been 

thoroughly investigated as new drugs, their safety for use under medical supervision is not 

determined. In addition, adverse consequences thought to be related to abuse of UR-144, 

XLR11 and/or AKB48 are documented in case reports. Serious adverse effects including 

tachycardia, agitation, seizures and/or death have been reported following the ingestion of UR144, XLR11 and/or AKB48. Thus, there is a lack of accepted safety for use of these substances

under medical supervision.
28

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37

Appendix 1

Public Health

1. The Substance Abuse and Mental Health Services Administration (SAMHSA) 

reported that in 2010, an estimated 11,406 emergency department visits involved a 

synthetic cannabinoid product.

2. SAMHSA reported that in 2011, an estimated 28,531 emergency department visits 

involved a synthetic cannabinoid product, a significant increase over the 2010 

estimated visits.

3. Monitoring the Future study results for 2012 (released 12/19/2012) state that for the 

second year of reporting, use of synthetic [cannabinoids] marijuana amongst 12th

graders held level at 11.3%. Study authors stated that while a leveling was 

encouraging, the high prevalence rate despite Federal and State efforts to reduce its 

use was troublesome.

4. Monitoring the Future study results for 2013 (released 12/18/2013) state that use of 

synthetic marijuana amongst 12th graders fell from 11.3% in 2012 to 7.9% in 2013.

5. Health effects (as described by the AAPCC) from synthetic cannabinoids can be lifethreatening and can include:

a. Severe agitation and anxiety.

b. Fast, racing heartbeat and higher blood pressure.

c. Nausea and vomiting.

d. Muscle spasms, seizures, and tremors.

e. Intense hallucinations and psychotic episodes.

f. Suicidal and other harmful thoughts and/or actions.

g. http://www.aapcc.org/alerts/synthetic-marijuana/

6. ...these substances are among the worst they have ever seen. People high on these 

drugs can get very agitated and violent, exhibit psychosis and severe behavior 

changes, and have harmed themselves and others. Some have been admitted to 

psychiatric hospitals and have experience continued neurological and psychological 

effects (News Release–American Association of Poison Control Centers: AAPCC 

Issues Statement on the Synthetic Drug Abuse Prevention Act, July 11, 2012).

7. Synthetic cannabinoids, commonly known as “synthetic marijuana,” “K2,” or 

“Spice,” are often sold in legal retail outlets as “herbal incense” or “potpourri”. They 

are labeled “not for human consumption” to mask their intended purpose and avoid 

Food and Drug Administration (FDA) regulatory oversight of the manufacturing 

process. (Office of National Drug Control Policy)

8. At least 43 states have taken action to control one or more synthetic cannabinoids. 

(Office of National Drug Control Policy, 2014)

9. Spice users report experiences similar to those produced by marijuana—elevated 

mood, relaxation, and altered perception—and in some cases the effects are even 

stronger than those of marijuana. Some users report psychotic effects like extreme 

anxiety, paranoia, and hallucinations. (National Institute on Drug Abuse, 2014)

10. Spice abusers who have been taken to Poison Control Centers report symptoms that 

include rapid heart rate, vomiting, agitation, confusion, and hallucinations. Spice can 

also raise blood pressure and cause reduced blood supply to the heart (myocardial 

ischemia), and in a few cases it has been associated with heart attacks. Regular users 
38

may experience withdrawal and addiction symptoms. (National Institute on Drug 

Abuse, 2014)

11. In order to protect public health and well-being, Governor Maggie Hassan today 

declared a State of Emergency in the State of New Hampshire as a result of recent 

overdoses in Manchester and Concord as a result of the use or misuse of the 

synthetic cannabinoid identified as "Smacked!”. (Press Release: Governor Hassan 

Declares State of Emergency as a Result of Overdoses from Synthetic Cannabinoid –

August 14, 2014)

12. CESAR FAX, a publication from the Center for Substance Abuse Research at the 

University of Maryland (College Park), reported the results from Bonar et al. (2014) 

describing the results of the study of patients in a Midwestern residential treatment 

program. Results demonstrated that 71% of those reporting synthetic cannabinoid 

abuse used an SC-containing product to avoid a positive drug test. The two most 

common reasons for SC use was “curiosity” (91%) and “to feel good or get high” 

(89%). (September, 2014)

Poison Control Centers

1. From January 1, 2011 through December 31, 2011, poison centers nationwide 

have received 6,968 exposure calls regarding exposure to synthetic cannabinoids.

2. From January 1, 2012 through December 31, 2012, poison centers nationwide 

have received 5,230 exposure calls regarding exposure to synthetic cannabinoids.

3. From January 1, 2013 through December 31, 2013, poison centers nationwide 

have received 2,668 exposure calls regarding exposure to synthetic cannabinoids.

4. From January 1, 2014 through December 31, 2014, poison centers nationwide 

have received 3,680 exposure calls regarding exposure to synthetic cannabinoids.

5. From January 1, 2015 through February 28, 2015, poison centers nationwide 

have received 623 exposure calls regarding exposure to synthetic cannabinoids.
39

Appendix 2

STRIDE and NFLIS Encounters

Table 8a. NFLIS – State, Local, and other Federal National Forensic Laboratory Information 

System (NFLIS) Reports for 2010 (Queried on April 30, 2015)

2010 Total

Q1 Q2 Q3 Q4

 JWH-018 

JWH-073

 JWH-200 

CP-47,497

 CP-47,497 

C8 homologue

138 413 670 1197 2418

UR-144

XLR11

AKB48

1* 0 0 0 1

*Encounter confirmed in Mar 2012; # = data is incomplete for 2013 Q1, still being reported

Table 8b. NFLIS – State, Local, and Other FederalNational Forensic Laboratory Information 

System (NFLIS) Reports for 2011 (Queried on May 6, 2013)

2011 Total

Q1 Q2 Q3 Q4

 JWH-018 

JWH-073

 JWH-200 

CP-47,497

 CP-47,497 

C8 homologue

1,515 994** 659 536 3,704

UR-144

XLR11

AKB48

0 0 0 50 50

** JWH-018, JWH-073, JWH-200, CP-47,497 and CP-47,497 C8 homologue were placed under emergency 

schedule I of the CSA on March 1, 2011.
40

Table 8c. NFLIS – State, Local, and other Federal National Forensic Laboratory Information 

System (NFLIS) Reports for 2012(Queried on April 30, 2015)

2012 Total

Q1 Q2 Q3 Q4

 JWH018; 

JWH-073;

 JWH200; 

CP-47,497

 CP47,497 

C8 

homologue

426 341 233 150 1,146

UR-144; 

XLR11;

AKB48

548 3,368 6,306 5,257 15,479

Table 8d. NFLIS – State, Local, and other Federal National Forensic Laboratory Information 

System (NFLIS) Reports for 2010 (Queried on April 30, 2015)

2013 Total

Q1 Q2 Q3 Q4

 JWH-018 

JWH-073

 JWH-200 

CP-47,497

 CP-47,497 

C8 homologue

110 97 83 57 347

UR-144

XLR11

AKB48

6,733 6,616 3,954 2,838 20,141
41

Table 8e. NFLIS – State, Local, and other Federal National Forensic Laboratory Information 

System (NFLIS) Reports for 2010 (Queried on April 30, 2015)

2014 Total

Q1 Q2 Q3 Q4

 JWH-018 

JWH-073

 JWH-200 

CP-47,497

 CP-47,497 

C8 homologue

68 29 16 11 124

UR-144

XLR11

AKB48

3,672 3,092 2,482 1,407 10,653

Table 8f. NFLIS – State and Local National Forensic Laboratory Information System (NFLIS) 

Reports 2010-2014 Total (Queried on April 30, 2015)

2010 2011 2012 2013 2014 Total

 JWH018; 

JWH-073;

 JWH200; 

CP-47,497

 CP47,497 

C8 

homologue

2,418 3,704 1,150 347 124 7,743

UR-144; 

XLR11;

AKB48

1 50 15,479 20,141 10,653 46,324

Table 9. STRIDE and STARLiMS Records (January 1, 2010 through December 31, 2014*#):

CASES RECORDS

AKB48 63 201

UR-144 245 2,049

XLR11 487 4,041

* No reports identified in STRIDE regarding UR-144, XLR11 or AKB48 prior to January 2010

# Multiple records in STRIDE contained a combination of AKB48, UR-144 or XLR11

STRIDE collected the results of drug evidence analyzed at DEA laboratories and reflects evidence submitted by the 

DEA, other Federal law enforcement agencies, and some local law enforcement agencies. STRIDE data were 

queried through 09/30/2014 by date submitted to Federal forensic laboratories. On October 1, 2014, STARLiMS 

replaced STRIDE as the DEA laboratory drug evidence data system of record. 
42

Table 10. States reporting encounters to NFLIS, state, local, and other Federal data16

Alabama Alaska Arizona Arkansas

California Colorado Connecticut Florida

Georgia Hawaii Idaho Illinois

Indiana Iowa Kansas Kentucky

Louisiana Maine Maryland Massachusetts

Minnesota Missouri Mississippi Nebraska

Nevada New Hampshire New Mexico North Carolina

North Dakota Ohio Oklahoma Oregon

Pennsylvania South Carolina Tennessee Texas

Utah Virginia Wisconsin Wyoming

New Jersey New York Washington West Virginia

Table 11. Selected Reports from Customs and Border Protection Laboratory (August 2012

– December 2014)

Date of 

Detention

Identified 

Substance(s)

Detained 

at

Originated 

from Destination

TOTAL 

WEIGHT

8/22/2012 UR-144, URB602, 

URB754 (mixture)

Honolulu 

Intl Mail

unknown Sun City, AZ unknown

9/12/2012 XLR11 Domestic 

seizure

China Rancho 

Cordova, CA

2 kg

9/12/2012 AKB48 San 

Francisco 

Intl Mail

China Las Cruces, 

NM

2 kg

10/5/2012 XLR11 San 

Francisco 

Intl Mail

China Tustin, CA 3 kg

10/11/2012 XLR11 San 

Francisco 

Intl Mail

China Sugarland, CA 6 kg

10/11/2012 XLR11 San 

Francisco 

Intl Mail

China Houston, TX 6 kg

10/11/2012 XLR11 San 

Francisco 

Intl Mail

China Stafford, TX 6 kg

10/11/2012 XLR11 San 

Francisco 

Intl Mail

China Houston, TX 6 kg

10/18/2012 UR-144 San 

Francisco 

China Las Cruces, 

NM

1 kg

 

16 NFLIS data queried April 30, 2015 for the period between January 2010 and December 2014.
43

Intl Mail

10/18/2012 AKB48 San 

Francisco 

Intl Mail

China Las Vegas, NV 1.5 kg

10/18/2012 XLR11 San 

Francisco 

Intl Mail

China Houston, TX 3 kg

10/18/2012 XLR11 San 

Francisco 

Intl Mail

China Montebello, 

CA

3 kg

10/26/2012 AKB48 San 

Francisco 

Intl Mail

China Hammond, LA 4 kg

10/26/2012 XLR11 San 

Francisco 

Intl Mail

China El Monte, CA 4 kg

11/2/2012 UR-144 San 

Francisco 

Intl Mail

China Las Cruces, 

NM

1 kg

11/8/2012 UR-144 San 

Francisco 

Intl Mail

China Las Cruces, 

NM

1 kg

11/8/2012 UR-144 San 

Francisco 

Intl Mail

China Las Cruces, 

NM

1.5 kg

11/8/2012 UR-144 San 

Francisco 

Intl Mail

China Rowlett, TX 2 kg

11/29/2012 UR-144 San 

Francisco 

Intl Mail

China Spokane, WA 500 grams

11/29/2012 XLR11 San 

Francisco 

Intl Mail

China Ogden, UT 500 grams

12/6/2012 UR-144 San 

Francisco 

Intl Mail

China Las Cruces, 

NM

1 kg

12/6/2012 XLR11 San 

Francisco 

Intl Mail

China Sanford, FL 3 kg

12/20/2012 XLR11 FedEx 

Anchorage, 

AK

China Bellrose, NY 2 kg

12/28/2011 UR-144 UPS 

Ontario 

unknown Las Vegas, NV unknown
44

(LA 

Transfer)

12/31/2012 XLR11 San 

Francisco 

Intl Mail

China Los Angeles, 

CA

1 kg

12/31/2012 AKB48 San 

Francisco 

Intl Mail

China Los Angeles, 

CA

1 kg

12/31/2012 XLR11 San 

Francisco 

Intl Mail

China Houston, TX 1 kg

12/31/2012 XLR11 San 

Francisco 

Intl Mail

China Houston, TX 1 kg

12/31/2012 AKB48 San 

Francisco 

Intl Mail

China Denham 

Springs, LA

1 kg

1/7/2013 UR-144 San 

Francisco 

Intl Mail

China Las Cruces, 

NM

1 kg

1/7/2013 XLR11 San 

Francisco 

Intl Mail

China Los Angeles, 

CA

2 kg

1/7/2013 AKB48 San 

Francisco 

Intl Mail

China Los Angeles, 

CA

1 kg

1/18/2013 UR-144 San 

Francisco 

Intl Mail

China Los Angeles, 

CA

2 kg

1/18/2013 XLR11 San 

Francisco 

Intl Mail

China Houston, TX 1 kg

1/18/2013 XLR11 San 

Francisco 

Intl Mail

China Richmond, TX 2 kg

1/18/2013 AKB48 San 

Francisco 

Intl Mail

China Springfield, 

MO

1 kg

1/18/2013 UR-144 San 

Francisco 

Intl Mail

China Los Angeles, 

CA

2 kg

1/24/2013 XLR11 San 

Francisco 

Intl Mail

China Fullerton, CA 1 kg

1/24/2013 XLR11 San 

Francisco 

China Perris, CA 2 kg
45

Intl Mail

1/24/2013 XLR11 San 

Francisco 

Intl Mail

China Pleasanton, 

TX

2 kg

1/24/2013 XLR11 San 

Francisco 

Intl Mail

China Lubbock, TX 1 kg

1/24/2013 XLR11 San 

Francisco 

Intl Mail

China Lubbock, TX 1 kg

1/24/2013 XLR11 San 

Francisco 

Intl Mail

China Tulsa, OK 2 kg

1/24/2013 XLR11 San 

Francisco 

Intl Mail

China Perris, CA 2 kg

1/24/2013 XLR11 San 

Francisco 

Intl Mail

China Perris, CA 2 kg

1/24/2013 XLR11 San 

Francisco 

Intl Mail

China Fullerton, CA 2 kg

1/24/2013 XLR11 San 

Francisco 

Intl Mail

China Fullerton, CA 2 kg

1/24/2013 XLR11 San 

Francisco 

Intl Mail

China Perris, CA 2 kg

2/7/2013 XLR11 San 

Francisco 

Intl Mail

China Lawndale, CA 1 kg

2/13/2013 UR-144 San 

Francisco 

Intl Mail

China Freeland, WA 1 kg

2/13/2013 XLR11 San 

Francisco 

Intl Mail

China Albuquerque, 

NM

600 grams

2/20/2013 XLR11 San 

Francisco 

Intl Mail

China Park City, UT 1.3 kg

2/20/2013 UR-144 San 

Francisco 

Intl Mail

China Salt Lake City, 

UT

600 grams

2/28/2013 XLR11 San 

Francisco 

China Bellingham, 

WA

1.2 kg
46

Intl Mail

2/28/2013 XLR11 San 

Francisco 

Intl Mail

China Houston, TX 1.6 kg

2/28/2013 UR-144 San 

Francisco 

Intl Mail

China Las Cruces, 

NM

1.5 kg

2/28/2013 AKB48 San 

Francisco 

Intl Mail

China Bainbridge 

Island, WA

1.3 kg

2/28/2013 AKB48 San 

Francisco 

Intl Mail

China Newman Lake, 

WA

300 grams

3/6/2013 UR-144 San 

Francisco 

Intl Mail

China Houston, TX 1.2 kg

3/13/2013 UR-144 Domestic 

seizure

unknown Anchorage, 

AK

50 grams

3/21/2013 XLR11 FedEx 

Anchorage, 

AK

China Santa Rosa, 

CA

7.8 kg

3/27/2013 XLR11 San 

Francisco 

Intl Mail

China Las Vegas, NV 1.2 kg

3/29/2013 UR-144 San 

Francisco 

Intl Mail

China Pineville, LA 500 grams

3/29/2013 UR-144 San 

Francisco 

Intl Mail

China Boise, ID 500 grams

3/29/2013 XLR11 San 

Francisco 

Intl Mail

China Pflugerville, 

TX

1 kg

3/29/2013 AKB48 San 

Francisco 

Intl Mail

China Pflugerville, 

TX

1 kg

4/10/2013 XLR11 San 

Francisco 

Intl Mail

China Houston, TX 3 kg

4/10/2013 XLR11 San 

Francisco 

Intl Mail

China Houston, TX 3 kg

4/10/2013 XLR11 San 

Francisco 

China Houston, TX 3 kg
47

Intl Mail

4/10/2013 XLR11 San 

Francisco 

Intl Mail

China Houston, TX 3 kg

4/17/2013 XLR11 San 

Francisco 

Intl Mail

China Houston, TX 3 kg

4/17/2013 XLR11 San 

Francisco 

Intl Mail

China Houston, TX 3 kg

4/17/2013 XLR11 San 

Francisco 

Intl Mail

China Stockton, CA 2 kg

4/17/2013 XLR11 San 

Francisco 

Intl Mail

China Millbrae, CA 2 kg

4/17/2013 XLR11 San 

Francisco 

Intl Mail

China Millbrae, CA 2 kg

4/17/2013 XLR11 San 

Francisco 

Intl Mail

China Stockton, CA 2 kg

4/17/2013 XLR11 San 

Francisco 

Intl Mail

China Stockton, CA 2 kg

4/17/2013 XLR11 San 

Francisco 

Intl Mail

China Stockton, CA 2 kg

4/17/2013 XLR11 San 

Francisco 

Intl Mail

China Stockton, CA 2 kg

4/17/2013 XLR11 San 

Francisco 

Intl Mail

China Millbrae, CA 2 kg

4/17/2013 XLR11 San 

Francisco 

Intl Mail

China Millbrae, CA 2 kg

4/17/2013 XLR11 San 

Francisco 

Intl Mail

China Millbrae, CA 2 kg

4/17/2013 XLR11 Memphis 

TN Fed Ex

China Salt Lake City, 

UT

3.5 kg

4/25/2013 XLR11 San 

Francisco 

Intl Mail

China New Mexico 500 grams
48

4/25/2013 XLR11 San 

Francisco 

Intl Mail

China Stockton, CA 2 kg

4/25/2013 XLR11 San 

Francisco 

Intl Mail

China Stockton, CA 2 kg

4/29/2013 XLR11 San 

Francisco 

Intl Mail

China St. George, UT 4 kg

4/29/2013 XLR11 San 

Francisco 

Intl Mail

China Millbrae, CA 2 kg

4/29/2013 XLR11 San 

Francisco 

Intl Mail

China Chapparal, 

NM

1 kg

4/29/2013 XLR11 San 

Francisco 

Intl Mail

China Clearfield, UT 500 grams

5/6/2013 XLR11 San 

Francisco 

Intl Mail

China Stockton, CA 2 kg

5/6/2013 XLR11 San 

Francisco 

Intl Mail

China Stockton, CA 2 kg

5/6/2013 XLR11 San 

Francisco 

Intl Mail

China Millbrae, CA 2 kg

5/6/2013 XLR11 San 

Francisco 

Intl Mail

China Millbrae, CA 2 kg

5/6/2013 XLR11 San 

Francisco 

Intl Mail

China Clearfield, UT 500 grams

5/10/2013 XLR11 San 

Francisco 

Intl Mail

China Houston, TX 3 kg

5/10/2013 XLR11 San 

Francisco 

Intl Mail

China Danville, IL 500 grams

5/10/2013 UR-144 San 

Francisco 

Intl Mail

China Metairie, LA 10 grams

5/16/2013 UR-144 San 

Francisco 

Intl Mail

China Houston, TX 200 grams
49

5/16/2013 UR-144 San 

Francisco 

Intl Mail

China Houston, TX 5 kg

6/3/2013 UR-144 San 

Francisco 

Intl Mail

China El Paso, TX 400 grams

6/3/2013 UR-144 San 

Francisco 

Intl Mail

China Cypress, TX 100 grams

6/3/2013 XLR11 San 

Francisco 

Intl Mail

China Kansas City, 

KS

1 kg

6/13/2013 XLR11 San 

Francisco 

Intl Mail

China Delano, CA 1 kg

6/13/2013 XLR11 San 

Francisco 

Intl Mail

China Belano, CA 1 kg

6/13/2013 XLR11 San 

Francisco 

Intl Mail

China Seymour, TX 500 grams

7/1/2013 XLR11 FedEx 

Anchorage, 

AK

China Sanford, FL 3 kg

7/2/2013 XLR11 FedEx 

Anchorage, 

AK

China Sanford, FL 3.3 kg

7/10/2013 XLR11 San 

Francisco 

Intl Mail

China Kansas City, 

KS

1 kg

8/22/2013 XLR11 San 

Francisco 

Intl Mail

China New Laney, 

TX

200 grams

8/22/2013 XLR11 San 

Francisco 

Intl Mail

China Casper, WY 1 kg

9/12/2013 XLR11 San 

Francisco 

Intl Mail

China Raton, NM 1 kg

10/3/2013 XLR11 San 

Francisco 

Intl Mail

unknown unknown 3.3 kg

10/3/2013 XLR11 San 

Francisco 

Intl Mail

unknown unknown 1 kg
50

10/17/2013 XLR11 San 

Francisco 

Intl Mail

China Salt Lake City, 

UT

2 kg

10/17/2013 XLR11 San 

Francisco 

Intl Mail

China Englewood, 

CO

1 kg

11/19/2013 XLR11 San 

Francisco 

Intl Mail

China Canyon 

Country, CA

2 kg

11/19/2013 XLR11 San 

Francisco 

Intl Mail

China Canyon 

Country, CA

3 kg

11/19/2013 XLR11 San 

Francisco

Intl Mail

China Canyon 

Country, CA

2 kg

11/19/2013 AKB48 San 

Francisco 

Intl Mail

China Albuquerque, 

NM

3 kg

11/19/2013 AKB48 San 

Francisco 

Intl Mail

China Albuquerque, 

NM

3 kg

12/5/2013 UR-144 San 

Francisco 

Intl Mail

China Hidalgo, TX 200 grams

1/2/2014 XLR11 San 

Francisco 

Intl Mail

China Los Angeles, 

CA

1 kg

3/20/2014 XLR11 San 

Francisco 

Intl Mail

China Caguas, PR 4 kg

3/27/2014 XLR11 San 

Francisco 

Intl Mail

China Salt Lake City, 

UT

1 kg

3/27/2014 XLR11 San 

Francisco 

Intl Mail

China Houston, TX 1 kg

4/10/2014 UR-144 San 

Francisco 

Intl Mail

China Los Angeles, 

CA

1 kg

4/17/2014 XLR11 San 

Francisco 

Intl Mail

China Colorado 

Springs, CO

1 kg

4/29/2014 XLR11 San 

Francisco 

Intl Mail

China Houston, TX 1 kg
51

5/8/2014 XLR11 San 

Francisco 

Intl Mail

China Marmaduke, 

AR

20 grams

5/15/2014 XLR11 San 

Francisco 

Intl Mail

China Sand Springs, 

OK

6 grams

5/15/2014 XLR11 San 

Francisco 

Intl Mail

China Los Angeles, 

CA

1 kg

6/10/2014 XLR11 San 

Francisco 

Intl Mail

China Buena Park, 

CA

4 kg

6/6/2014 XLR11 San 

Francisco 

Intl Mail

China Sand Springs, 

OK

6 grams

7/3/2014 XLR11 San 

Francisco 

Intl Mail

China Albuquerque, 

NM

200 grams

7/22/2014 XLR11 FedEx 

Anchorage, 

AK

China Recifel Pina, 

Brazil

20 grams

7/24/2014 XLR11 San 

Francisco 

Intl Mail

China Albuquerque, 

NM

1 kg

7/31/2014 XLR11 San 

Francisco 

Intl Mail

Hong 

Kong

Trumbull, CT 2 kg

7/31/2014 UR-144 San 

Francisco 

Intl Mail

Hong 

Kong

Trumbull, CT 1 kg

7/31/2014 XLR11 San 

Francisco 

Intl Mail

China Fountain 

Valley, CA

1 kg

8/19/2014 XLR11 San 

Francisco 

Intl Mail

China Houston, TX 3 kg

8/26/2014 XLR11 San 

Francisco 

Intl Mail

China Thomasville, 

GA

200 grams

9/2/2014 XLR11 San 

Francisco 

Intl Mail

China Fountain 

Valley, CA

1 kg

9/16/2014 XLR11 FedEx 

Anchorage, 

AK

China Louisville, KY 1 kg
52

9/16/2014 XLR11 San 

Francisco 

Intl Mail

China Dallas, TX 10 grams

9/26/2014 XLR11 Oakland 

FedEx

China Astoria, NY 1 kg

10/15/2014 XLR11 San 

Francisco 

Intl Mail

China Albany, CA 10 grams

10/21/2014 XLR11 San 

Francisco 

Intl Mail

China Hartingen, TX 1 kg

10/21/2014 XLR11 San

Francisco 

Intl Mail

China Buena Park, 

CA

2 kg

10/21/2014 XLR11 San 

Francisco 

Intl Mail

China Anaheim, CA 1 kg

10/21/2014 XLR11 San 

Francisco 

Intl Mail

China Oakland, CA 150 grams

10/30/2014 XLR11 San 

Francisco 

Intl Mail

China Jefferson, LA 1 kg

11/4/2014 XLR11 San 

Francisco 

Intl Mail

China Los Angeles, 

CA

1 kg

12/16/2014 XLR11 San 

Francisco 

Intl Mail

China Bakersfield, 

CA

1 kg

12/23/2014 XLR11 San 

Francisco 

Intl Mail

China Donna, TX 400 grams

12/23/2014 XLR11 San 

Francisco 

Intl Mail

China Donna, TX 500 grams