investigative report bestkusuri/bestkenko august 2015 · representation of mhlw directives and...

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LegitScript | Internet Pharmacy Verification 818 SW 3rd Ave. #353, Portland, Oregon 97204 877-534-4879 (tel), 503-914-0308 (fax) [email protected] Investigative Report BestKusuri/BestKenko August 2015

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Page 1: Investigative Report BestKusuri/BestKenko August 2015 · representation of MHLW directives and domain name suspension requests to the hundreds of domain name registrars around the

LegitScript | Internet Pharmacy Verification 818 SW 3rd Ave. #353, Portland, Oregon 97204

877-534-4879 (tel), 503-914-0308 (fax) [email protected]

Investigative Report BestKusuri/BestKenko

August 2015

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Contents  

Appendix  A:   BestKenko  Domain  Name  Workup  (DNW)  Appendix  B:   Singapore  Licensed  Pharmacies  

1.0     BestKusuri/BestKenko  —  Illegal  Drug  Sales  TargeGng  the  Japanese  Market   3         ...................2.0     Japanese  RegulaGon  of  Online  Drug  Sales  and  Personal  ImportaGon   7         .............................3.0     Origin  and  Ownership  of  the  BestKusuri/BestKenko  Network   9         .........................................4.0     Singapore  Dispensing  Center  and  Drug  Sourcing   14         .............................................................

4.1     Scanpro  Pacific  Pte.  Ltd.   14       ..............................................................................................

4.2     Vista  Pharma   15       ...............................................................................................................

4.3     Alps  Pharmacy  aka  Anam  Trading  Pte.  Ltd.  aka  Anam  Pharmacy   16       ................................

4.4     SAVA  Global   17       .................................................................................................................

4.5     VaijanG  Pharmacy   18       ........................................................................................................

4.6     AdverGsed  Medicines     20       .................................................................................................5.0     Domain  Name  RegistraGon  and  Website  OperaGon   23         ........................................................6.0     Website  Content   24         ..............................................................................................................7.0     Payment  and  Merchant  Accounts   27         ....................................................................................8.0     Conclusion   29       ........................................................................................................................

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1.0     BestKusuri/BestKenko  —  Illegal  Drug  Sales  Targe<ng  the  Japanese  Market  

This report describes the operations of the largest rogue Internet pharmacy network

targeting Japan: the “BestKenko” (previously, “BestKusuri”) group of websites. It outlines the

history of the network, describes the nature of its legal violations, and identifies the principal

individuals who run the network — Singapore-based Mark RADFORD and Robin

SCRIMGEOUR, Japan-based partner Joel DEVIDAL, and India-based drug suppliers SAVA

Global and Vaijanti Pharma — and their shell companies.

As background, Japan’s pharmaceutical market is the second-largest in the world,

following the United States. The size of the Japanese market makes it an attractive target market

for sellers and suppliers of unregulated prescription drugs. The majority of sellers are affiliates of

organized, illegal Internet pharmacy affiliate networks whose owners, affiliates, and drug

suppliers illegally import unregulated drugs into Japan in violation of Japanese health and

pharmacy policies and laws.

In Japan, the Japanese Ministry of Health, Labor and Welfare (MHLW) is the national

agency responsible for protecting and promoting the health and welfare of Japanese citizens.

Japan has some of the strictest drug safety laws in the world, and LegitScript has been retained

by MHLW to identify and expedite the shutdown of websites that facilitate illegal Internet drug

sales. LegitScript’s activities to curtail illegal online drug sales on behalf of MHLW include

representation of MHLW directives and domain name suspension requests to the hundreds of

domain name registrars around the world that operate under accreditation by the Internet

Corporation for Assigned Names and Numbers (ICANN).

In 2013, LegitScript reviewed 2,345 individual Japanese-language search results that

referred to websites that marketed prescription drugs to Japanese consumers. LegitScript 1

http://www.legitscript.com/download/Japanese%20Threat%20Assessment%202013%20Update%20ENGLISH1

%20Version.pdf

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research showed that less than 0.1 percent of these 2,345 search results promoted or linked to

Internet pharmacies that operate in compliance with MHLW policies and regulations. In other

words, more than 99.9 percent of the search results referred to Internet pharmacies that operated

in compliance with MHLW policies and regulations. LegitScript found that 44 percent of these

illegal pharmacy websites were operated by only three distinct pharmacy networks. LegitScript

refers to these three networks, listed in order of size, as:

• BestKenko, previously known as BestKusuri, based in Singapore;

• Roy Union, based in China; and

• RxCash.biz, with network management based in Israel and customer service operations

located in Ukraine.

BestKenko, formerly known as the BestKusuri network, claims to be Japan’s largest

health-related Internet shopping network, and LegitScript’s analysis indicates that the network is

the largest illegal online pharmacy network targeting Japan. BestKenko website content is

written in the Japanese language and generally, the websites use Internet traffic control

technologies based on Internet Protocol (IP) addresses to restrict display of the pharmacy content

to browsers that use a Japanese IP address, in a process known as geo-targeting.

In 2012, LegitScript worked with domain name registrars to suspend the domain name

registrations for several Internet pharmacy websites operating under the flagship “BestKusuri”

brand. This rendered the BestKusuri websites invisible to Internet users. In response, the network

changed its primary brand name to BestKenko and found new domain name registrars that would

protect BestKenko domain name registrations from suspension requests.

BestKenko sells both human and pet prescription medicines that include a large number

of unapproved drugs — that is, drugs that are not approved and regulated by the Japanese

government for safety and authenticity. BestKenko aggressively operates Internet pharmacies in

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violation of Japanese laws and regulations by selling unapproved drugs without a prescription 2

that are shipped directly to Japanese consumers from a dispensing pharmacy and fulfillment

center in Singapore. Every product page (including those with supplements) shows the following

image with text in the Japanese language that among other claims states, “All the products can be

delivered anywhere in the country without prescription.”

Fig 1: BestKenko Service Guarantees

!

LegitScript continues to monitor BestKenko Internet activity for the Japanese MHLW.

BestKenko currently operates hundreds of management-owned and affiliate pharmacy and

referral websites and continually registers new domain names to maintain and increase its

Internet footprint. LegitScript’s database contains a list of more than 800 active BestKenko

pharmacy and affiliate referral websites. The majority of these websites redirect customer orders

to a very small number of flagship order-processing websites, that include the BestKenko

flagship Internet pharmacy website bestkenko.com, a sister company “Medicine Express” 3

flagship website, kusuriexpress.com, the veterinary “PetKusuri” flagship website, petkusuri.com,

and a second veterinary brand flagship, genkipet.co.

The Japanese MHLW has authorized LegitScript to pursue suspension of BestKenko

domain name registrations and online merchant processing services as a way to curtail the

activity of the network. Despite these efforts, the network has found “safe haven” with a few

See, for example, the no prescription statement at http://www.bestkenko.com/products/2

%E3%83%91%E3%83%AD%E3%82%AD%E3%82%BB%E3%83%81%E3%83%B320mg.html http://besutokenkou001.zouri.jp/kaisyagauyou.html3

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registrars, including Tucows in Canada, that refuse to suspend the domain name registrations

used by BestKenko for its flagship Internet pharmacy websites. These same few registrars allow

the network to register new domain names using a variety of business names and anonymous

registration services. The BestKenko practice of using a variety of registered and non-registered

business names and anonymous postal mail services to hide the network ownership, supplier

structure, and their true operational locations makes shutdown of the network operations

additionally difficult.

The remainder of this report describes the illegal nature of the BestKenko operations, the

network owners, investors and affiliates, the drug suppliers and dispensing pharmacies,

LegitScript’s recent activities in shutting down the merchant account used by the network for

online payment processing, and the network’s ongoing domain name registration and active

website operations.

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   2.0     Japanese  Regula<on  of  Online  Drug  Sales  and  Personal  Importa<on  

Japanese policies and laws regarding Internet marketing are stringent: as a general rule,

prescription medicines cannot be sold over the Internet in Japan and no licensed Japanese

pharmacy is permitted to sell prescription drugs online or to actively market unapproved drugs to

Japanese customers via the Internet. This far-reaching policy is, however, complicated by a legal

loophole, or exception, that permits personal importation of prescription drugs in exceedingly

narrow circumstances. The exception is limited, and is written to permit a small degree of

prescription drug importation, and is permitted only if the Internet pharmacy website does not

advertise drugs and display drug images that are unapproved by Japanese laws and regulations.

To fully comply with guidance issued by the MHLW, the website sales activities must be

“passive” — that is, the website cannot actively attract Japanese customers by advertising

unapproved drugs by drug specific text or images, for this exception to apply; otherwise, the

prescription drug importation exception is not allowed. This drug importation exception in

Japanese regulation is presumably intended for the purchase of drugs from a pharmacy that is

known to be a safe and appropriately licensed pharmacy in the country in which it operates ––

for example, a licensed, safe pharmacy in the US. The reality is that far less than 1 percent of

websites that target Japanese consumers with drug images and text and that facilitate the

importation of drugs into Japan actually adhere to the importation exception and other health and

pharmacy policies and regulations issued by the MHLW. None of BestKenko’s websites come

close to complying.

None of the BestKenko websites that market unapproved medicines to Japanese

customers adhere to the narrow nature of the personal drug importation exception, although the

websites claim –– inaccurately –– that their websites are legal because “prescription drug

importation is permitted in Japan.” This is an inaccurate interpretation of the importation

exception and, in all other respects, a violation of the Japanese prohibition of active Internet

marketing and sale of unapproved drugs. Additionally, BestKenko websites that actively market

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and sell unapproved drugs to Japanese consumers do not dispense drugs from legitimate,

licensed pharmacies in the US or other countries, despite the website text and images that claim

the drugs they sell are approved drugs that are dispensed from legitimate, licensed pharmacies.

The BestKenko “Beginners Guide,” which is made available to Internet users as a top 4

menu choice on the bestkenko.com website, disavows any responsibility for ensuring that

prescription drugs sold by the network can be legally purchased by Japanese consumers. The

guide claims that the sole responsibility for a legal purchase lies with the end consumer, who

must buy the drugs under a Japanese personal importation exception law. BestKenko

inaccurately represents that this personal exemption allows Japanese consumers to import drugs

from other countries, and in the case of BestKenko, the drugs are sourced in India and dispensed 5

from a fulfillment center in Singapore. BestKenko’s description of the Japanese personal drug 6

import exception is an invalid interpretation of Japanese law. (Note: BestKenko does not limit its

sales to individuals — the network offers special buyer memberships to doctors and clinics for

wholesale purchase of prescription drugs for discounted rates and statements on bestkenko.com

indicates that network has offered medicines to Japanese cosmetic clinics.) 7

http://www.bestkenko.com/pages/初めての方へ.html4

http://www.bestkenko.com/pages/EDのジェネリック薬の現状は?.html?submit=agree5

http://www.bestkenko.com/pages/%E3%81%94%E5%88%A9%E7%94%A8%E3%82%AC6

%E3%82%A4%E3%83%89.html?submit=agree http://www.bestkenko.com/pages/doctors.html/?submit=agree7

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3.0     Origin  and  Ownership  of  the  BestKusuri/BestKenko  Network  

The BestKenko network was founded in 2009 using the branding BestKusuri and

PetKusuri. The network changed its human medicines group name to BestKenko after

LegitScript successfully shut down the flagship and namesake Internet pharmacy websites in

2012. The network retained the animal pet medication group name of PetKusuri, but collectively

the network is referred to in the remainder of this report as BestKenko or BestKusuri/BestKenko.

Sometime after the websites using the “BestKusuri” name brand were shut down, the

BestKenko network added a “sister” human medicines group, Medicine Express, and a second

pet medicine group, GenkiPet. Collectively, these Internet brands are part of the BestKenko

network, which operates under the umbrella of a Singapore private investment firm, Rajah Blue

Holdings Pte. Ltd. Rajah Blue maintains a portfolio of its private investment businesses, which

include a Singapore business named Scanpro Pacific Pte. Ltd. Scanpro Pacific and Rajah Blue

directors operate the Singapore distribution center that stores and ships BestKenko drugs.

Another Rajah Blue business, Ichikado, Ltd., owns the BestKenko brand names, and the

directors of Rajah Blue work with silent partners or investors to operate the BestKenko affiliate

network and drug supply chain. In July 2015, a Rajah Blue director registered a new company,

Sakura United Ltd, in the UK and that name now appears on some versions of bestkenko.com.

The medicines sold by BestKenko are supplied by one or more entities in India, including SAVA

Global, a contract drug manufacturer and drug import/export company and, more recently in

2015, an India drug distributor known as Vaijanti Pharmacy, which is affiliated with a group of

India doctors who operate a small hospital in India.

This section describes the individuals who own and manage the BestKenko affiliate

marketing, sales, dispensing, and shipping operations. The following section describes the

network supply and distribution network that is controlled in India by SAVA Global and its

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subsidiary SAVA Intertrade FZE located in the United Arab Emirates (UAE) and by India-based

Vaijanti Pharmacy and pharmacist-in-charge Amruta Kenge Desphande.

BestKusuri was established as a three-party equal-share ownership between the 8

Singapore-based distribution company Scanpro Pacific Pte. Ltd. (scanpropacific.com and

scanpro.co.sg) and the individuals Joel DEVIDAL (jooto.com and zaporo.com) and Mark

RADFORD (Facebook, LinkedIn, Knowesis). DEVIDAL and RADFORD partnered in the

international marketing company DialUsNow, which was registered as DialusNow, Ltd. in the 9 10

UK and simultaneously registered in Singapore as DialUsNow Pte. Ltd. The DEVIDAL and 11

RADFORD partnership includes US real estate investments in Florida and possibly Michigan,

under the Florida registered company Sakusen Investments, LLC. 12

Partners DEVIDAL and RADFORD are Internet marketing, technology, and

telecommunication entrepreneurs who continually form new companies that target the Japanese

market. Their customers are both the end-consumers who purchase the medicines sold by the

BestKenko network and other entrepreneurial individuals or businesses who want to do business

in Japan. DEVIDAL and RADFORD operate using a variety of dba names, including

Dialusnow (dialusnow.com — offline) and Onenrg (onenrg.com , — offline). RADFORD 13 14 15

also does business as Bushido Enterprises (bushido-enterprises.com — offline), a dba name 16

that was displayed on bestkenko.com, until late July 2015. On July 20, 2015, Robin Macdiarmid

Campbell SCRIMGEOUR (Facebook, LinkedIn), a director of Rajah Blue, registered Sakura

http://companycheck.co.uk/director/913650329/JOEL--DEVIDAL/group-structure8

Archive domain name registrations - Bushido Enterprises - Radford9

http://companycheck.co.uk/company/06826918/DIALUSNOW-LTD/directors-secretaries10

Singapore Government E-Service Directory of Registered Entities11

State of Florida (sunbiz.org) - Sakusen Investments, LLC12

http://www.petkusuri.com/pages/Shipping%20&%20Returns.html13

https://web.archive.org/web/20091222081435/http://www.onenrg.com/14

https://web.archive.org/web/20130803114718/http://kamome.cn/docs/1838815

Archive domain name registrations - Bushido Enterprises - Radford16

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United Ltd., in the UK. This new business name has replaced Bushido Enterprises on 17

bestkenko.com, as shown in the screenshots of bestkenko.com below. 18

Fig 2: Screenshots of bestkenko.com, Trade and Owner Name Display page

Affiliate referral websites that link to bestkenko.com may continue to refer to Bushido

Enterprises. 19

Scanpro Pacific and, by extension, the BestKenko network operate under the umbrella of

Rajah Blue Holdings Pte. Ltd. aka Rajah Blue Capital (rajahblue.com), a Singapore private

portfolio investment business that identifies Scanpro Pacific as one of its portfolio companies.

Additionally, Ichikado, UK, and Ichikado, Hong Kong, identified in PetKusuri terms of 20

operation and as the owner of the PetKusuri trademarks, are controlled by Rajah Blue director 21

Robin SCRIMGEOUR, who is also the registered director of Sakura United, Ltd., shown in the

previous screenshots of bestkenko.com.

bestkenko.com - July 16, 2015 bestkenko.com - July 28, 2015

��

http://www.bestkenko.com/pages/%E7%89%B9%E5%AE%9A%E5%95%86%E5%8F%96%E5%BC17

%95%E6%B3%95%E3%81%AB%E5%9F%BA%E3%81%A5%E3%81%8F%E8%A1%A8%E7%A4%BA.html http://www.bestkenko.com/pages/特定商取引法に基づく表示.html18

See, for example, www.beyondareasonabledoubtmovie.com.19

http://companycheck.co.uk/company/08140548/ICHIKADO-LTD/directors-secretaries20

http://www.petkusuri.com/pages/Terms%20of%20Use.html21

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SCRIMGEOUR’s registration of Ichikado, UK is significant: several pages on the

PetKusuri website, including the Japanese-language version of the Terms page, identify the

owning company as Ichikado, UK and the dispensing pharmacy as Alps Pharmacy. Archive 22

records show that the BestKusuri/BestKenko network has used the PetKusuri merchant name to

process online credit card transactions for both BestKusuri/BestKenko and PetKusuri websites

since 2010. In other words, the PetKusuri merchant account has been in continuous use for 23

online credit card purchases for both pet and human medications sold by the BestKusuri/

BestKenko network since 2010 or earlier, and Ichikado, UK controls the PetKusuri brand. (Note

that in July 2015, LegitScript, working with Visa, requested suspension of the PetKusuri credit

card merchant account sponsored by banks.. More information about the network’s payment

processing and merchant accounts is provided later in this report.)

LegitScript believes that DEVIDAL, RADFORD, SCRIMGEOUR, and their business

partners have used the offshore and shelf company services business Offshore Incorporations HK

Limited (offshore-inc.com and oilglobal.com) to incorporate and register their various dba

business names in the British Virgin Islands (BVI), Hong Kong, Mauritius, UK, and US

jurisdictions. The loss of the PetKusuri Visa merchant account was temporary — the business 24

obtained another merchant account, which at the time of this writing LegitScript is in the process

of shutting down — and over 800 BestKenko pharmacy and referral websites remain online and

appear to continue to accept customer orders at the time of this report.

RADFORD’s and SCRIMGEOUR’s LinkedIn profiles are shown on the following page.

https://www.petkusuri.com/pages/%E7%89%B9%E5%AE%9A%E5%95%86%E5%8F%96%E5%BC22

%95%E6%B3%95%E3%81%AB%E5%9F%BA%E3%81%A5%E3%81%8F%E8%A1%A8%E7%A4%BA.html https://web.archive.org/web/20100324175558/http://www.petkusuri.com/manualBK/23

http://www.oilglobal.com/jurisdictions24

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Fig 3: Mark Radford LinkedIn profile Fig 4: Robin Scrimgeour LinkedIn profile

!

!

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4.0     Singapore  Dispensing  Center  and  Drug  Sourcing  

Drugs sold by the BestKenko network are supplied by two companies in India, SAVA

Global (savaglobal.com) and Vaijanti Pharmacy (vaijantipharma.com — offline). The drugs are

shipped from India to Sharjah Airport International Free Zone (SAIF Zone) in the UAE. From

there, the drugs are shipped, warehoused, and dispensed from a fulfillment center in Singapore to

customers in Japan. BestKenko claims that its Singapore distribution center is certified by the

Singapore government and that it supplies more than 2,000 different drugs where the dispensing

operations are supervised by a staff of 12 pharmacists. (That this is almost certainly untrue is 25

underscored by the fact that the network sells drugs unapproved in both Japan and in Singapore,

such as Kamagra.) A YouTube video posted on the PetKusuri flagship website, petkusuri.com,

shows outgoing orders labeled as shipping to Singapore.

4.1 Scanpro Pacific Pte. Ltd.

The BestKenko Singapore distribution and shipping company is identified on the

PetKusuri websites as Scanpro Pacific Pte. Ltd. Scanpro Pacific 26

(scanpropacific.com) is a Singapore company that describes it business as a multi-line

distributor and retailer of industrial and consumable products, including

pharmaceuticals. Scanpro is a portfolio company of the private investment firm Rajah

Blue Holdings Pte. Ltd. (rajahblue.com). LegitScript reviewed Singapore government

records for licensed pharmacies, licensed pharmacists, and licensed medicine

importers and wholesalers, and did not find records that indicate Scanpro Pacific is

licensed in Singapore to operate a pharmacy or drug import and export business. A 27

YouTube video posted on the PetKusuri flagship website, petkusuri.com, shows the

http://www.bestkenko.com/pages/%E3%81%94%E5%88%A9%E7%94%A8%E3%82%AC25

%E3%82%A4%E3%83%89.html http://www.petkusuri.com/pages/Shipping%20&%20Returns.html26

http://www.hsa.gov.sg/content/hsa/en/Health_Products_Regulation/27

Info_search_for_Health_Products_and_Services.html

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distribution center packaging process with outgoing orders placed in a mail bag

labeled “Singapore.” 28

4.2 Vista Pharma

Some BestKenko domain name registrations provide a clue as to the licensed

Singapore pharmacies and pharmacists that the BestKenko network claims to employ.

Vista Pharma, a BestKenko domain registrant, provides a postal street address at “91

Alps Avenue,” in Singapore. This address is part of a Federal Express mail center

located just outside the Singapore airport. 29

A search of Singapore registered businesses did not return any records for Vista

Pharma. However, an address search of pharmacies licensed by the Singapore

government identified two pharmacies, Alps Pharmacy and WestMead Pharmacy, at 30

“91 Alps Avenue.” Vista Pharma and Alps Pharmacy have the same street and box

address, “91 Alps Avenue, #03-01,” and LegitScript believes that Vista Pharma is a

another dba name used by SAVA Global to do business as the Singapore licensed

pharmacy, Alps Pharmacy. Westmead Pharmacy (westmeadpharmacy.com) describes

itself as a fulfillment center pharmacy, but uses a different post office box than Vista

Pharma and Alps Pharmacy, “91 Alps Avenue, #03-10.” The managing pharmacist of

Westmead Pharmacy is Foo Ah Lan JOYCE, whose Singapore pharmacist license 31

shows that JOYCE is employed by the Singapore chain store pharmacy Guardian

Health & Beauty (guardian.com.sg). Review of the Guardian website shows a fleeting

entry on their store locator map for 91 Alps Avenue. 32

https://www.youtube.com/watch?v=OIjIkvYdSVY28

http://www.fedex.com/sg/dropoff/29

Search for “Alps”: http://eservice.hsa.gov.sg/prism/common/enquirepublic/SearchPharmacy.do?action=load30

Search for “Foo Ah Lan Joyce”: https://prs.moh.gov.sg/prs/internet/profSearch/main.action?hpe=SPC31

Search map for close-up of the Singapore airport: http://www.guardian.com.sg/store-finder32

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4.3 Alps Pharmacy aka Anam Trading Pte. Ltd. aka Anam Pharmacy

Singapore business registration records show that Alps Pharmacy was formerly 33

known as Anam Trading Pte. Ltd. (Google+) aka Anam Pharmacy. Anam Pharmacy is

known by LegitScript to be a former subsidiary of SAVA Global, the India-based drug

manufacturer and import/export drug wholesaler that provides drugs and fulfillment

services to several unapproved and rogue online pharmacy networks. In a patent 34

infringement lawsuit in the US, Bayer identified Anam Pharmacy as a dispensing

pharmacy of counterfeit or trademark-infringing drugs sold by Canadian mail-order

pharmacies, and other named defendants included Ronin Ventures, a business 35

named used by Joel DEVIDAL and Yuko Tanaka to register one or more original

BestKusuri domain names.

Alps Pharmacy (alps-pharmacy.sg) is a fulfillment pharmacy that is known to

dispense drugs for one or more of the unapproved Canadian mail-order pharmacies,

in particular the Solaris network, which lists Alps Pharmacy as a dispensing

pharmacy on its order forms. Confidential sources have informed LegitScript that 36

Vinod JADHAV owns one of the Solaris network websites and that Solaris controls 37

and advises other Canadian mail-order pharmacies. In hidden content on the Alps

Pharmacy website, it claims that it is an approved PharmacyChecker foreign 38

pharmacy. 39

Search for “Alps Pharmacy”: https://www.psi.gov.sg/NASApp/tmf/TMFServlet?app=RCB-BIZFILE-LOGIN-1B33

https://blog.legitscript.com/2012/10/bestkusuri-com-japanese-rogue-pharmacy-linked-to-singapore-internet-firms/34

http://www.law360.com/cases/4e6fa22a904343530c00000435

See Solaris network partners pharmacies: http://www.canadapharmacyonline.com/docs/Orderform.pdf36

See www.globaldrugsdirect.com.37

https://www.legitscript.com/about/setting-the-record-straight/38

See Google cache copies of alps-pharmacy.sg (for example, Google cache July 6, 2015).39

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In Singapore, LEE Kim Siong Peter, aka Peter LEE Kim Siong, aka Peter LEE

(LinkedIn) is licensed as the managing pharmacist of Anam Trading Pte. Ltd. LEE 40

also does business as Lindee Enterprises, a Singapore wholesale pharmaceutical

business. Another pharmacist, Lee Swan KEE, is also licensed by the Singapore

government as an Alps Pharmacy pharmacist and as a pharmacist doing business as

FP Marketing (S) Pte. Ltd. (Google+). 41

An undated Singapore government spreadsheet of licensed Singapore pharmacies,

which contains entries for Alps Pharmacy and Westmead Pharmacy, is attached to this

report as Appendix B.

4.4 SAVA Global

Vinod JADHAV (Facebook, LinkedIn, Yatedo) is the founder of SAVA Global

(savaglobal.com), which is also known as SAVA Healthcare, Ltd. and SAVA Group. 42

SAVA Global is based in India and operates drug and dietary supplement

manufacturing and import/export subsidiaries or partnerships in India, Asia, Russia,

and the US. In Singapore, SAVA Global does business as SAVA Medica (Singapore)

Pte. Ltd., and the pet medicines labeled “SAVAVET” in the petkusuri.com video are 43

produced by SAVAVET (savavet.com), another SAVA Global subsidiary.

Although SAVA Global claims to be a drug manufacturer, further research indicates

that the company primarily operates as a contract manufacturer that uses low-cost

third-party manufacturers to produce the generic and research drugs and dietary

supplements SAVA provides to its partner businesses. SAVA Global operates its

foreign subsidiaries in partnership with other businesses such as Alps Pharmacy in

Search for “Alps Pharmacy”: https://www.psi.gov.sg/NASApp/tmf/TMFServlet?app=RCB-BIZFILE-LOGIN-1B40

https://prs.moh.gov.sg/prs/internet/profSearch/main.action?hpe=SPC41

http://indiankanoon.org/doc/116902325/?type=print42

http://savaglobal.com/global-offices.html 43

http://savaglobal.com

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Singapore, the mail-order Canadian pharmacy known to LegitScript as Solaris, and

the US-based dietary supplement business, Savesta (savesta.com), which is a joint

venture with Avesthagen, India (avesthagen.com), the owner of the US manufacturing

facility.

Additional indication of SAVA Global’s association with the BestKenko network as a

supplier, seller, and network owner is shown in several BestKenko domain name

registrations. The SAVA Global domain name registrations include:

• domain name registrations by registrant Vista Pharma using the Alps

Pharmacy aka Anam Pharmacy postal address in Singapore.

• historical, non-anonymous domain name registrations that identify the

registrant as Anagha Pharma, a SAVA Global subsidiary. These domain 44

names include the flagship Internet pharmacy websites bestkenko.com,

kusuriexpress.com, and petkusuri.com. For more information, see the

“Explanatory Notes” in Appendix A: BestKenko Domain Name Workup.

• current and historical domain name registrations that use either a Sharjah

Airport International Free Zone (SAIF) in UAE postal address, or the name of

the SAVA Global transshipment center, SAVA Intertrade FZE, for example

vistapharma.biz.

4.5 Vaijanti Pharmacy

In early 2015, a new domain name registrant, Vaijanti Pharmacy, appeared in

BestKenko domain name registrations. In response to LegitScript monitoring and

domain name suspension activities on behalf of Japan’s MHLW, LegitScript was

contacted by a Canadian attorney representing Vaijanti Pharmacy, the India company

that claims to be the current licensed pharmacy dispensing drugs for the BestKenko

http://www.savaglobal.com/awards-accolades.html44

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network. The India pharmacy license and the pharmacist-in-charge license for

Vaijanti Pharmacy is issued to Mrs. Amruta Kapil DESHPANDE nee Amruta Krishna

KENGE. Although Vaijanti Pharmacy is licensed in India, the business is not itself a

registered India corporation. LegitScript research indicates that Vaijanti Pharmacy is

not a traditional retail pharmacy in the sense that it serves individual patients, but

rather it operates as an India stockist, a specific type of warehouse and export 45

clearing and forwarding agent in India that is used by pharmaceutical manufacturers

to handle drug distribution.

Amruta DESHPANDE and her husband, Kapil Jayant DESHPANDE, use a 46

common telephone number (+91.9850146471 or, alternatively, 9850146471). This

telephone number is associated with the Vaijanti stockist business, and beginning in 47

2015, it is also used in BestKenko domain name registrations by Vaijanti Pharmacy,

India or Vista Pharma, Singapore. Prior to 2015, Vista Pharma had been associated

with SAVA Global. The relationship, if any, between Vaijanti Pharmacy and SAVA

Global is unknown to LegitScript at the time of this report.

Vaijanti Pharmacy shares a postal address and business name with the registered 48

India business Ekdant Enterprises Pvt. Ltd. The five directors of Ekdant are doctors,

serving on the board of CIIGMA Institute of Medical Sciences Pvt. Ltd.

(ciigmahospital.org), a small hospital in Pune, India. The Ekdant directors are 49

Mandar Suresh Abhyankar, Pushpa Ravindra Kodlikeri, Vaishakh Pralhad Palsodkar,

Unmesh Vidyadhar Takalkar, and Mrs. Manisha Unmesh Takalkar. It is not known at

https://www.dolcera.com/wiki/index.php?title=Indian_Pharma_Industry_-_Distribution_45

%26_Sales_Force_Structure http://www.consumercomplaints.in/profile-103213446

http://aeranlab.com/NEW%20STOCKIST%20LIST.pdf47

https://www.zaubacorp.com/company/EKDANT-ENTERPRISES-PRIVATE-LIMITED/48

U74999PN2012PTC144010 http://www.ciigmahospital.org/chief_con.html49

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the time of this report whether Ekdant Enterprises operates as an agent for CIIGMA

hospital, or as a subsidiary of SAVA Global, or as a partner or owner of Vaijanti

Pharmacy.

4.6 Advertised Medicines

BestKenko claims the network sells more than 2,000 different drugs in the following

condition or treatment categories:

• Alzheimer’s • Anti-aging • Antibiotics • Beauty and skin treatments • Contraceptives • Depression/Anxiety • Diabetic • Diet • Hair growth and care • High blood pressure • Himalayan dietary supplements • Hormones • Insomnia • Pain analgesics • Sexual dysfunction and enhancement • Smoking cessation

The flagship bestkenko.com website displays a large number of pharmaceutical,

veterinary, and dietary supplement company logos. The display includes 50

BestKenko’s own generic brand logo, SAVA Global brand logo, and, inexplicably, the

logo for the UK’s Medicines and Healthcare Products Regulatory Agency (MHRA).

BestKenko claims that the drugs it sells are drugs from regulated and reputable drug

manufacturers. However, some of the human and pet medicines include BestKenko

and SAVA Global brand versions of generic drugs. The BestKenko and SAVA brand

http://www.bestkenko.com/brands/50

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drugs are not known to be approved by health authorities in Japan, Singapore, or

India.

The integrity of the drug supply chain is also unknown. BestKenko’s own description

of its supply chain, and additional LegitScript research, indicate that the drugs

sourced in India are processed through SAVA Global and Vaijanti Pharmacy

intermediary warehouses in India and the UAE, and then shipped to the Scanpro

fulfillment center in Singapore, before the drugs are ultimately sold to Japanese

customers.

The table below lists the advertised manufacturers and suppliers that are displayed on

the “Brands” page of bestkenko.com.

BestKenko Advertised Drug Manufacturers and Suppliers

Abbott Laboratories F. Hoffmann-La Roche AG, Switzerland Pierre Fabre Laboratories

AFT Pharmaceuticals, Australia and New Zealand FDC Pvt. Ltd., India Q-Med, a Galderma company,

Switzerland

Ajanta, India Glenmark RPG Life

Akums Drugs & Pharmaceuticals, Ltd.

Hisamitsu Pharmaceutical Co., Inc., Japan

Sava Healthcare, Sava Medical, India

Albert David Ltd., India Ind-Swift Limited Schering Plough

Albion Indi Pharma Source Naturals

Allergan Infinity Industries Sun Pharma/Ranbaxy, India

Alums, UK Intas T.O.Chemicals

Astrazeneca Leading Edge Health and Leading Edge Herbal, US and UK

Taisho Pharmaceutical Co., Ltd., Japan

Aventis Lundbeck Takeda, Japan

BestKenko Lupin Pharmaceuticals, Inc. The Himalaya Drug Company, India

Bexmico Pharmaceuticals, India Macleods Pharmaceuticals Pvt Ltd. UCB, S.A., Belgium

Boehringer Ingelheim GmbH, Germany

Meda Pharmaceuticals, Meda AB, Sweden

Unichem Laboratories, Ltd., India

Daiichi Sankyo Healthcare Company, Japan

Medicines and Healthcare Products Regulatory Agency (MHRA), UK Unicure

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Eli Lilly & Company, USAMerck Sharp & Dohme Corp., a subsidiary of Merck & Co., Inc., USA

USV Ltd., India

Em Cure Merial Sanofi, France Win Medicare Pft., Ltd., India

Envy Medical Inc. Micro Labs Ltd., India Windlas BioTech Pvt. Ltd., India

EyeFive, US Novo Nordisk, Denmark Wyeth, now part of Pfizer, US

JAGSONPAL pharmaceuticals OLIC (Thailand) Limited Zydus Pharmaceuticals (USA), Inc.

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5.0     Domain  Name  Registra<on  and  Website  Opera<on  

The majority of BestKenko domain name registrations are anonymous. The small number

of non-anonymous domain registrations, along with references on the pet medication websites to

a Singapore distribution center managed by Scanpro Pacific and similar reference on those

websites to Ichikado, Ltd., the payment and trademark owner, provides information that

identifies the principal network owners or managers as Joel DEVIDAL, Mark RADFORD, and

Robin SCRIMGEOUR and their India-based partners and drug suppliers, SAVA Global and

Vaijanti Pharmacy. To a lesser extent the non-anonymous domain name registrations identify

individual affiliates or the small Internet marketing, web design, and Internet hosting firms that

support BestKenko website operations or work as BestKenko network affiliates.

Appendix A: BestKenko Domain Name Workup (DNW) contains a list of the pharmacy

and affiliate referral websites that currently make up the BestKenko network. The DNW

spreadsheet provides a list of the domain names and website URLs, the domain name registrant

names, postal addresses, telephone numbers, and email addresses, referred to as WHOIS data.

The DNW also provides information about website Internet addresses and the Internet service

providers that enable BestKenko websites to appear on the Internet.

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6.0     Website  Content  

The BestKenko network, as monitored by LegitScript, has over 800 active websites in

July 2015. These websites include the four flagship pharmacy “brand” websites (bestkenko.com,

kusuriexpress.com, petkusuri.com, and genikpet.co) which are the ultimate order-processing and

Internet traffic redirection targets for the hundreds of affiliate pharmacy referral websites; blog

pages and websites that LegitScript has identified and cataloged; and the anchor websites that do

not sell drugs but are used for other purposes to manage the network. BestKenko sells both

human and pet medicines. The flagship human medicine pharmacy websites are bestkenko.com

and kusuriexpress.com — bestkenko.com represents the network namesake “BestKenko” brand,

and kusuriexpress.com represents the sister brand “Medicine Express.” Both of the human

Internet pharmacy websites have a unique acceptance page that requires potential customers to

accept or decline BestKenko terms before the pharmacy catalog and images can be displayed.

This acceptance page is one method the network uses to claim it is operating in compliance with

Japanese laws and regulations. However, the MHLW has confirmed that this confirmation page

does not make the website legal. See screenshot below.

Fig 5: BestKenko website entry acceptance screen (source: bestkenko.com/templates/bk3/images/welcome.jpg)

!

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Below are full-page screenshots of the four BestKenko flagship Internet pharmacy

websites.

Fig 6: Screenshots of flagship BestKenko pharmacy websites

From the perspective of the average Japanese Internet user, the BestKenko websites seem

eminently reassuring. For example, the home page of bestkenko.com shows three Japanese

physicians smile out at the Internet user, next to an image offering “100% assurance” of drug

authenticity, effectiveness and delivery. The website, written entirely in flawless Japanese, offers

bestkenko.com kusuriexpress.com petkusuri.com genkipet.co

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assurances to “first time customers” that the website is completely legal, and offers –– mostly, at

least –– pristine pictures of familiar Japanese medicines. The customer is told that the medicines

have been approved for safety by the US Food and Drug Administration. The prices are in yen, 51

and a page offers multiple testimonials, apparently from Japanese residents, as to their

satisfaction regarding the medicines provided by bestkenko.com. To any Japanese Internet user,

it would seem that bestkenko.com offers a fully legal, entirely safe, website selling prescription

medicines, marrying the best of the Internet with online healthcare fully regulated for safety.

The truth, however, is starkly different. In fact, bestkenko.com has no affiliation

whatsoever with any Japanese physician or pharmacy, despite the marketing. The drugs are not,

for the most part, approved for sale in Japan, and are not sold by any licensed pharmacy in Japan

or any other location. Although the website claims that the medicines have been approved for

safety by government agencies such as the US Food and Drug Administration, most of the drugs

sold on the BestKenko websites are not approved by the US Food and Drug Administration.

http://www.bestkenko.com/pages/%E9%85%8D%E9%80%81%E6%96%99%E9%87%91%E3%81%AB51

%E3%81%A4%E3%81%84%E3%81%A6.html http://www.bestkenko.com/kb/search/%E3%83%88%E3%83%A9%E3%83%83%E3%82%AD%E3%83%B3%E3%82%B0

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7.0     Payment  and  Merchant  Accounts  

BestKenko allows customers to pay for their orders using credit card or bank transfer

payments. Accepted credit cards are Visa, JCB, and American Express (AMEX). As previously

mentioned in Section 3, describing the network operators, BestKenko has used the merchant

name PetKusuri as its primary merchant account name for Visa and AMEX cards, and it is used

for both pet and human medicine credit card payments. The merchant account names that are

used for JCB credit card payments include PetKusuri and a second merchant name, GenkiPet.

Specifically, the JCB credit card merchant accounts are identified as

AW*petkusuri.com6567777683 and AW*genkipet.co6567777683 on petkusuri.com and 52 53

genkipet.co, respectively.

The Singapore telephone number +65.67777683, represented in the PetKusuri and

GenkiPet billing descriptors above, is also used in the domain name registration for

petkusuri.info, where the registrant is Vista Pharma (aka Alps Pharmacy). Like petkusuri.com,

the genkipet.co website identifies Robin SCRIMGEOUR’s Ichikado, Ltd. as the management

company. 54

In July 2015, LegitScript worked with Visa to terminate the BestKenko merchant account

identified as PetKusuri. The merchant identifier was WWW.PETKUSURI.COM and was

identified as being serviced by a Luxembourg bank, Catella Bank S.A. An unverified online

response to the termination of the merchant account concluded that the network had been

closed. This seems premature: subsequent LegitScript review of the flagship Internet pharmacy 55

http://www.petkusuri.com/pages/%E3%81%8A%E6%94%AF52

%E6%89%95%E3%81%84%E6%96%B9%E6%B3%95%E3%81%AB%E3%81%A4%E3%81%84%E3%81%A6.html http://www.genkipet.co/terms-and-conditions53

http://www.genkipet.co/terms-and-conditions54

http://医薬品輸入代行.com/55

%E3%83%99%E3%82%B9%E3%83%88%E3%82%B1%E3%83%B3%E3%82%B3%E3%83%BC%E3%81%8C%E9%96%89%E9%8E%96.html

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payments. As this report was being finalized, LegitScript identified four new merchant identifiers

used by BestKenko: RNOP 0000-000-000, MTUM 0000-000-000, MNO 0000-000-000 and

GDL 0000-000-000 (“0” refers to numbers that are assigned by BestKenko; thus, “0” may be

replaced by other digits on a credit card statement). We are still researching the new acquiring

bank providing payment processing services to the network.

BestKenko network payments made to affiliates are transferred using Paypal

(paypal.com). The BestKenko affiliate PayPal merchant account is unknown to LegitScript but

will be researched and identified in the near future.

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8.0     Conclusion  

BestKenko is a network of illegal online pharmacies targeting Japan operated by a small

group of private investors that includes Singapore-based Mark RADFORD and Robin

SCRIMGEOUR, Japan-based partner Joel DEVIDAL, and India-based drug suppliers SAVA

Global and Vaijanti Pharma. RADFORD has a professional background in marketing and

telecommunications sales prior to his involvement with such startup and small companies as

OneNrg and DialUsNow, the founding business of the BestKusuri/BestKenko network.

RADFORD partnered with DEVIDAL in DialUsNow. DEVIDAL’s expertise is Internet coding,

Internet payment gateways, small-business startup, and affiliate marketing. Robin

SCRIMGEOUR, a Director of Rajah Blue Holdings and the registrant of Ichikado, Ltd., the

BestKenko trademarks and payments owner, worked in investment banking and equity trading

before moving to private capital investing, most recently with Rajah Blue Holdings Pte. Ltd., the

investment company that manages the BestKenko distribution partner, Scanpro Pacific Pte. Ltd.

Both SCRIMGEOUR and RADFORD are directors of Rajah Blue, which RADFORD describes

as “… a diverse range of investments across different geographies on behalf of the stakeholders,

invests in seed-stage startups and operates an active business incubator from its shared service

facility in Singapore.” With this type of business description, the Singapore partners are able to 56

attract a variety of affiliates who work in Japanese and Pan-Asian markets.

Review of the current BestKenko domain name registrants in the BestKenko DNW, along

with LegitScript current and historical correspondence with individuals who are involved in

registration of BestKenko domain names and the operation of the associated websites, indicates

that the BestKenko network is able to attract two types of affiliates. The first type includes

Internet marketing and service providers who may believe they are working with a legitimate

https://sg.linkedin.com/pub/mark-radford/9/813/71756

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business. This first group of affiliates includes Pagerise Pty Ltd. (pagerise.com — offline) , 57 58

which corresponded with LegitScript regarding the original BestKusuri websites and a current

Japanese affiliate, Apple Seeds (a-seeds.com), an Internet marketing service company that

operates the customer recruitment website daisuki-pet.com. The second group of affiliates

identified in the BestKenko DNW operate websites that affiliate with multiple illegal Internet

pharmacy networks that target Japan, including the Roy Union and RxCash.biz networks

mentioned at the beginning of this report and other Japanese-language networks such as Net

General Hospital. This second group of affiliates most likely know that by working with

BestKenko, they are working with a pharmacy network that illegally sells drugs to Japanese

customers. These affiliates, whose names appear in some of the BestKenko non-anonymous

domain name registrations, include Yugo Hosado (Facebook), Jun Saito, and Osamu Makino.

Neither group of affiliates appear to control the operations of the BestKenko network.

The owners of the BestKenko network, including DEVIDAL, RADFORD,

SCRIMGEOUR, and the drug supply partners SAVA Global and Vaijanti Pharma, have operated

the BestKusuri/BestKenko network since at least 2010, and have done so despite legal actions

such as the Bayer intellectual property lawsuit and the website shutdowns requested by

LegitScript on behalf of the Japanese MHLW. The BestKenko network continues to be a major

health risk for Japanese consumers and remains a target for continued law enforcement and

private sector action intended to stop or curtail its illegal and prolific activities.

https://www.wantedly.com/companies/pagerise57

https://blog.legitscript.com/2012/10/bestkusuri-com-japanese-rogue-pharmacy-linked-to-singapore-internet-firms/58

L e g i t S c r i p t R e s e a r c h R e p o r t | B e s t K u s u r i / B e s t K e n k o | J u l y 2 0 1 5