stead, a single national shipping account, #22328, was being used by more than forty other drugstores. Collectively these pharmacies were shipping thousands of drug orders a week. “You could see that there were these pharmacies all over the country, shipping to customers all over the country,” Brill said.

The account had been registered and paid for by a company called RX Limited. There were several emails and two phone num- bers attached to the account, along with Florida and Texas ad- resses that both turned out to be “mail drops,” a kind of virtual mailbox bought over the Internet. RX Limited itself was registered as a corporation in Delaware. The organization clearly was trying to act like a legitimate American business, but from what Brill and Holdren could tell, it wasn’t any type of pharmaceutical company or wholesale distributor. Other than the mail drops, it seemed to have no real American presence at all.

Whatever RX Limited was, it was engaged in the distribution of a staggering amount of pharmaceuticals. Additional subpoenas produced still more spreadsheets, showing that account #22328 and others connected to it had been used by more than a hundred pharmacies since late 2006. “They were located in different parts of the United States,” Brill later testified. “They were smaller, inde- pendent pharmacies, so not things like CVS or Walgreens.” The investigators discovered that in one three-week period in 2007, these pharmacies had collectively shipped more than 57,000 drug orders. The math was mind-boggling: RX Limited was, at a mini- mum, responsible for shipping millions of orders of prescription drugs a year through FedEx.

The spreadsheets showed that the customers receiving the pills, like the pharmacies sending them, were scattered around the coun- try. Those customers’ orders rarely originated at their local phar- macies. An order placed online in Illinois was just as likely to be shipped from an RX Limited-connected pharmacy in Tennessee as from one down the street.

To understand how all this was possible, Brill and Holdren needed to get inside the pharmacies themselves. Over the next few