Case Study: Faegre Drinker Advises ASOP Global Foundation on Launch of Rx Watchdog Platform

Client:

Alliance for Safe Online Pharmacies (ASOP Global) Foundation

Industry:

Public Health | Pharmaceutical Regulatory

The Challenge

No comprehensive tool existed to continuously monitor the booming — and increasingly AI-accelerated — online market for prescription drugs sold by noncompliant sellers, despite rising consumer reliance on digital channels.

The online pharmaceutical marketplace has become one of the most pressing — and least visible — parts of consumer health in the United States. Thirty-eight percent of US adults now purchase prescription medicines online, and 51% incorrectly believe that only safe, verified sellers appear on the first page of search results. Among patients taking GLP-1 medications, 25% reported buying those drugs online. The trend is accelerating: the ASOP Global Foundation's 2025 U.S. Consumer Behavior Survey found that nearly three-quarters of online medicine buyers began purchasing within the previous three years.

At the same time, consumers increasingly rely on digital channels not just to buy medications but to research them. The EY US Consumer Health Survey 2026 found that 75% of US respondents have requested or would consider requesting a test, treatment, or prescription based on information found through search engines, and 55% said the same about information obtained through AI tools — with more than three-quarters viewing AI tools and search engines as reliable sources of health information. AI is also accelerating the speed and scale at which illegal online drug sellers can operate, creating new avenues of risk that outpace traditional enforcement.

Despite these trends, no comprehensive resource existed to continuously track how prescription medicines, investigational new drugs, and unapproved molecules are offered for sale from noncompliant sources across websites and social media. 

Point-in-time, product-specific snapshots — the prevailing approach — could not capture the scope or evolution of this rapidly shifting ecosystem. The ASOP Global Foundation, a 501(c)(3) nonprofit dedicated to combating the public health threat of illegal online drug sellers, needed a partner with deep experience at the intersection of pharmaceutical regulation, public health policy, and digital commerce to turn a problem into an operational platform.

The Approach

Faegre Drinker provided cross-disciplinary legal, regulatory, and policy guidance to help the ASOP Global Foundation design and launch Rx Watchdog as a first-of-its-kind monitoring platform.

Faegre Drinker worked alongside the ASOP Global Foundation and S-3 Research from concept through launch, advising on every phase of the initiative. The team helped shape Rx Watchdog's strategy, governance structure, and policy framework — navigating complex issues that span pharmaceutical regulation, consumer protection, online commerce, data sharing, and public health.

This was not a matter of applying a single area of legal skills. The engagement required integrating legal, policy, and consulting capabilities to align diverse stakeholders — including researchers, technologists, policymakers, and public health advocates — around a shared vision for a first-of-its-kind monitoring platform. Faegre Drinker brought the cross-disciplinary perspective necessary to transform an idea into a credible, sustainable public health tool designed for real-world impact.

The Results

Rx Watchdog has detected tens of thousands of potentially noncompliant products across 1,000+ domains, shifting the conversation from episodic snapshots to continuous, forward-looking data for policymakers and regulators.

Rx Watchdog is now live — the first public health monitoring platform to provide a dynamic, continuously updated view of how pharmaceutical products are advertised, promoted, and offered for sale online by seemingly noncompliant sellers. In its first quarter of data collection alone, the platform has already demonstrated the scale and interconnected nature of the problem:

• 41,514 product listings detected across monitored categories, spanning FDA-approved medications, investigational new drugs, and emerging molecules
• 1,035 domains identified offering prescription medications through seemingly noncompliant channels
• 1,751 social media posts from 406 unique sellers, generating 3,041 user interactions across multiple platforms
• 1,925 listings offering retatrutide — a drug that remains investigational and is not FDA-approved — across the web and social media
• 20,983 product listings for emerging peptide molecules that cannot legally be compounded today, across 330 domains
• 23% of seemingly noncompliant websites also had a detected social media presence, illustrating how sellers use multiple channels to broaden their reach
• 126 websites marketing products in both the metabolic and cancer categories, pointing to an ecosystem-level problem rather than a series of isolated, product-specific issues

The ASOP Global Foundation will use the platform to issue quarterly reports supporting research, public education, and engagement with policymakers, regulators, and law enforcement — filling a longstanding informational gap and equipping stakeholders with the data needed to promote a safer online marketplace for critical medicines. In fact, on the day of launch, 40 advocates joined ASOP Global Foundation to educate members of Congress and their staff on the issue and the need to protect patient safety online. 

Critically, Rx Watchdog moves the conversation from episodic, backward-looking research to continuous, forward-looking intelligence. For the first time, stakeholders can ask the questions that matter: Are the same accounts still active? Are the same domains still online? Are sellers shifting toward new high-demand medicines? Are the same websites offering products across very different therapeutic categories? The platform gives policymakers, regulators, and the public evidence that can support enhanced private-sector efforts or new enforcement actions — grounded not in a single snapshot, but in data that evolves alongside the threat.

“Tools like Rx Watchdog are long overdue. For too long, patients and regulators have lacked easy access to important information about prescription drugs. Rx Watchdog helps close that gap by providing clearer information, which can support safer decisions and a fairer marketplace for these important medicines.”

Libby Baney Burstein
Partner, Faegre Drinker

Faegre Drinker's government and regulatory affairs team and health and life sciences sector advise clients on the full spectrum of pharmaceutical regulatory, public health policy, and compliance matters. To learn more, contact the key professionals listed below.