stances Act, drugs that the government views as dangerous are classified according to five “schedules,” ranked roughly from most dangerous to least using Roman numerals I through V. Schedule I includes drugs that the U.S. government has deemed lack any med- ical application and have a high potential for abuse, including heroin and LSD. Schedule II drugs such as OxyContin and fen- tanyl, by contrast, have medical applications but retain a high po- tential for abuse and harm. Schedule III drugs are considered slightly less dangerous, and so on.

The RX Limited network of websites did not appear to traffic in scheduled drugs. Indeed, the websites themselves demonstrated a sharp awareness of the lines around U.S. drug law, with prominent disclaimers stating that they did not offer controlled substances. But evidence was growing that Ultram, Soma, and Fioricet weren’t, as commonly portrayed, “safe” alternatives to OxyContin. As far as Brill and Holdren were concerned, the drugs were “habit form- ing” at a minimum. RX Limited’s focus on these three painkillers, the investigators concluded, was a deliberate effort to avoid legal scrutiny.

If RX Limited was potentially skirting the law in one way, Brill and Holdren suspected it might be breaking it in others. For start- ers, Fioricet contained an ingredient that was controlled, a sched- ule III drug called butalbital. In Fioricet, it was mixed with caffeine and acetaminophen, the medication in Tylenol. Whether the com- bination met the criteria for a controlled substance wasn’t entirely clear, but it hardly mattered: As a technical, legal matter, even non- controlled drugs required a valid prescription to distribute. RX Lim- ited sites like Acmemeds.com seemed to acknowledge this reality as well, with prominent disclaimers: “Our company is committed to meeting and exceeding all Government regulations covering this new form of healthcare provision. Acmemeds.com will only refer your order to certified physicians that are fully licensed.”

Even if that were true—though the investigators strongly doubted it was—the volume of prescriptions flowing through the