Dear Mr. Pichai:
We are writing to express our deep concern about the role that internet search engines, such as Google, may play in facilitating the deadly drug trade. As such, we request that Google consider removing from its platform content that advertises the use of or enables the sale of illicit narcotics, including the sale of prescription drugs without a valid prescription. We further request that Google consider action to ensure that future, similar content is banned.
We understand that "Google restricts the promotion of online pharmacies," and that it bans "the promotion of substances that alter mental state for the purpose of recreation or otherwise induce "highs;" products or services marketed as facilitating recreational drug use; and the promotion of instructional content about producing, purchasing, or using recreational drugs."[1]
Despite this, the online sale of illicit narcotics, including the sale of prescription drugs without a valid prescription, is easily facilitated through the search engines of Google and other providers, as evidenced by the attachments to this letter and in a recent United States Senate Permanent Subcommittee on Investigations report.[2] Additionally, in 2015, the Global Drug Survey, which included 100,000 participants worldwide, found that nearly 12,000 respondents had purchased drugs online from conventional, surface websites as well as from "darknet" sites.[3]
As you may be aware, the Ryan Haight Online Pharmacy Consumer Protection Act, which was enacted in 2008, requires at least one in-person consultation with a physician in order to obtain a valid prescription to purchase a controlled substance through an online pharmacy. This law further requires all online pharmacies to register with the Drug Enforcement Administration, and to post basic information about their location, pharmacist in charge, and any physician with whom they are affiliated. Unfortunately, it appears that some of the pharmacies using Google to advertise their services are not in compliance with this law.
We recognize that not all purchases of illicit narcotics, to include prescription drugs without a valid prescription, are facilitated by Google's platform. However, Google can play a role in helping to stem the tide of overdose deaths associated with illicit drug use by ensuring its users cannot purchase such products using its platform. To that end, we request that you consider:
ensuring that when users search for medicines on your platform, they are automatically directed to websites connected to legal and legitimate pharmacies that require a valid prescription as a condition of sale;
disabling the ability to search for illicit drugs through your platform;
reporting to law enforcement authorities when Google receives information indicating that a company is advertising the use of or attempting to sell illicit narcotics or prescription drugs without a valid prescription online, and provide the relevant IP information;
establishing a 24/7 telephone point of contact whom law enforcement can directly communicate with regarding these instances (instead of an email point of contact); and
incorporating training for Google security reviewers (or their appropriate equivalent) to enable them to better recognize the companies purchasing domains through your search engine that promote or facilitate the online sale of illicit drugs and/or prescription drugs without a valid prescription.
Drug overdose deaths claimed the lives of nearly 64,000 Americans in 2016.[4] Based on the attachments and the data above, a portion of these substances may have been purchased via the internet, facilitated by illegitimate pharmacies exploiting online search engines. We cannot turn a blind eye to this activity.
We strongly request that you consider taking action. Thank you for your consideration of this very serious matter. We look forward to your reply.