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It has been more than two years since Scott Robinson surrendered to the Federal Bureau of Prisons to serve an 18-month sentence at a Florida facility. When he entered a guilty plea to one count of drug adulteration and misbranding conspiracy, he became the first of the defendants in the high-profile prosecution of some two dozen people connected with racehorse doping to give up the ghost.

According to prosecutors, Robinson and co-defendant Scott Mangini (who was also eventually sentenced to 18 months on a similar charge) worked together between 2011 and their indictment in 2020 to create, sell, and ship “millions of dollars’ worth of various misbranded and adulterated performance-enhancing drugs to customers across the United States and abroad.”

In addition to his prison sentence and three years of supervised release after prison, Robinson was ordered to forfeit more than $3.8 million to the government, representing his profits.

Mangini, who was once a licensed pharmacist, and Robinson, who has no veterinary or pharmacy degree or licenses, ran websites including HorsePreRace and HorseGold together until 2016, when they split and began running their businesses separately. Robinson continued his drug sales under the moniker RUI Labs while Mangini began selling via RacehorseMeds.com.

According to federal court records, Robinson was ordered to begin his sentence on Sept. 7, 2021, and Bureau of Prison records show a prisoner matching his name, age, and description as having been released on Nov. 18, 2022.

On Oct. 26, 2022, Robinson registered a business named Toltrazuril Shop LLC with the Florida Division of Corporations. The address listed on the registration was a house in Pace, Fla., which, according to county property records, is owned by his father -- Terry Lee Robinson -- and his stepmother.

ToltrazurilShop.com was registered as a website domain in early September 2022. Currently, the website sells a range of oral anti-parasitic or anti-protozoal medications that are marketed as being equally safe for use in horses, dogs, cats, goats, pigs, cattle, and other farm animal and pet species.

Product pages like the one for liquid toltrazuril contain the disclaimer “This statement has not been evaluated by the Food and Drug Administration. This product is not intended to diagnose, treat, cure, or prevent any disease,” alongside promises that the product is a “potent coccidiostat used to prevent and treat EPM in horses.”

A closer look at the labeling reveals the products available on Toltrazuril Shop may be produced and sold outside of FDA regulation.

Some of the products, like ivermectin, are available to horse and cattle owners over the counter, while others like ponazuril (the generic name for the equine EPM drug Marquis) require a prescription for legitimate, legal use.

None of the products on Toltrazuril Shop require users to provide a prescription or proof of veterinary licensure. Not only that, the shop offers customers the chance to become affiliates, earning them 20% commission for each sale they generate (presumably to other laypeople).

The products also don’t bear either NADA or ANADA numbers, which provide the consumer the reference number for the FDA’s approval of the drug maker to produce the product. NADA numbers are carried by pioneer drugs, while ANADA numbers are placed on legally-made generics. Pioneer drugs are the first form of an animal or human drug to be approved by the FDA, after having gone an extensive (and expensive) review process which gives the drug maker a temporary exclusive right to produce the product. Generics may be legally made by FDA-approved manufacturers after the pioneer drug maker’s exclusivity runs out. Generic drug production isn’t supposed to be a free-for-all, where the substance may be made by just anyone.

The products also don’t have NDC numbers, which stand for National Drug Code, indicating the product may be FDA-approved or that the FDA is aware of its production. These numbers should be present on all legally-produced drugs, including those which are legally sold over the counter.

The FDA approval process for drug makers exists to certify that the substance itself has been evaluated for safety and efficacy. The approval process for drug manufacturers is designed to require companies to meet rigorous standards for safety, purity, and traceability of ingredients and products, among other things.

Toltrazuril itself is a close relative of ponazuril and has no Food and Drug Administration-approved manufacturer for horses. As such, it can be legally compounded in a form of what the FDA calls “extra-label use,” but only by the order of a veterinarian who is treating a specific patient and ordering a specific amount from a licensed compounder.

“Extra-label use is limited to circumstances when the health of an animal is threatened, or suffering or death may result from failure to treat,” said Dr. Mary Scollay, chief of science for the Horseracing Integrity and Welfare Unit.

Scollay’s experience in her previous roles at the Racing Medication and Testing Consortium and the Kentucky Horse Racing Commission have provided her with many opportunities to see products that don’t adhere to FDA law.

“There are still so many people out there who believe generics are the same as products [like this] and they’re not,” she said. “If it doesn’t have an NADA or an ANADA number on it, you should be very suspicious.”

Robinson’s previous storefronts carried products with similar issues. He and Mangini got the most attention for injectable solutions with names like “Blast Off Red” and “Numb It” that were advertised to help horses run faster, longer, and ignore pain, but Mangini argued in his sentencing submission that it was drugs like the ones Toltrazuril Shop sells that made the most money. Omeprazole paste, which is used to treat gastric ulcers in horses and is available via Toltrazuril Shop, accounted for a quarter of his sales, while EPM drugs were 4.6 percent, according to court documents filed by Mangini. It’s likely Robinson’s sales distribution, though not mentioned in court documents, would have been similar.

When academic institutions and regulators have tested products like omeprazole and clenbuterol sold by online compounders, they frequently find the products contain wildly different concentrations of the active ingredients professed on the label – sometimes far less, and sometimes far more. That could be, in part, because the facilities making them aren’t subject to inspection to check labeling accuracy. Those concentration differences can mean a product is totally ineffective, or (in cases of higher concentrations) dangerous.

Toltrazuril Shop’s website boasts that it was established in 2021 by Yvette Pittman in Milton, Fla., using a formula developed in 2010 – despite the website not being registered until 2022. Pittman, who is billed as the company’s president, CEO, and COO, did not respond to an email request for comment on Robinson’s current role with the company.

An email and a voicemail to the company’s customer service department also went unanswered as of press time.

Florida Division of Corporation records show that Robinson dissolved the business’s registration on Dec. 18, 2023, indicating he had sold the company. The change came roughly a week after an anonymous whistleblower told the Paulick Report they had called the company to confront them about Robinson’s position. The Paulick Report has not been able to confirm whether the business has been re-registered with the state of Florida.

RacehorseMeds, Mangini’s former website, is dead, but HorsePreRace -- the site Robinson took over in 2016 -- lives on. (And also has its own affiliate program now, using an identical dashboard to Toltrazuril Shop.) It no longer markets injectable products, and has a significant catalog overlap with Toltrazuril Shop. It does still have a “performance supplements” section with four oral pastes bearing similar names to the injectables it used to sell (including Blast Off Distance and Energy Max). Their ingredient lists show honey and apple cider vinegar along with minerals as primary constituents.

It’s not clear where either company is sourcing the compounded products they’re selling, or even whether the person making them is a pharmacist. Mangini’s pharmacist license was put on probation in 2016 after his Ergogenic Labs failed a state inspection, and he voluntarily relinquished it in September 2022, agreeing never to reapply. HorsePreRace lists no physical address, and the one for Toltrazuril Shop goes to a UPS Store in Pace, Fla.

Scollay said it has become more common for online pharmacies like these to shift their focus from non-FDA-approved injectables to non-FDA-approved oral products. The FDA has its hands full monitoring human health and safety, and oral animal products are less likely to get a second look from federal law enforcement than an injectable with flashy marketing.

That doesn’t mean that products sold by this type of website are a good bet.

“These are unknowns,” said Scollay of products sold without the required FDA approval. “They are complete unknowns no matter what the label says, and I wouldn’t put any of them into any of my animals.

“Sites like this hurt animal health … they prey on the naivete of the consumer.”

Scollay said that most online compounders like this constitute their products from bulk ingredients, which was evident in the federal court record in the Mangini case, which included dozens of pages of receipts for drug ingredients purchased from China.

“There are risks in using bulk drugs,” she said. “Plenty of them come from Wuhan, China in big steel drums that could’ve been contaminated with other drugs. Salmonella, rat feces get in there. They could be degraded because of heat or moisture. It is not the equivalent of a generic in any capacity. from my perspective they are unknowns. Complete unknowns.”

Prior to his release from prison, Robinson gave interviews to the Thoroughbred Daily News’ Bill Finley, indicating he sold to “everybody” in the racing business and expressing frustration with the government’s definition of performance-enhancing drugs.

“Everybody else in here [at the Coleman facility] can go back to doing what they did before when they get out,” Robinson told Finley in early 2022. “When I get out, I don't have a job. This is what I did for the better part of 20 years. I've lost all of my racing licenses and I'll never again be able to own or train a horse.”

Federal prosecutors would probably say that if Robinson resumed his activities upon release, it wouldn’t be the biggest surprise. In their pre-sentencing report filed in March 2021, they revealed that Robinson’s business was searched by the FBI in September 2019, well before his indictment was unsealed in March 2020.

“Robinson, incensed by the FBI’s disruption of his illegal business, attempted to extort the federal agents involved in the seizure by threatening to release a letter to certain members of the racehorse industry informing them of the existence and scope of the FBI’s investigation if the FBI did not immediately return his electronic devices the same day they were seized,” the report read. “After being informed that his threat was itself a crime, Robinson retracted his threat hours later.”

In the time between September 2019 and his arrest in March 2020, prosecutors also say he had gone back to operating his businesses as usual, despite knowledge that law enforcement was investigating.

“I did wrong,” Robinson told the TDN two years ago. “I know that.”

This article first appeared on Paulick Report and was syndicated with permission.

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