On July 23, 2026, U.S. District Judge Robert J. Jonker sentenced Brandon Piper, 35, of Gobles, Michigan, to 21 months in federal prison. This article is based on the United States’ Sentencing Memorandum filed July 8, 2026 (United States v. Piper, No. 1:26-cr-00018-RJJ, W.D. Mich., ECF No. 20), signed by Assistant U.S. Attorney Stephanie M. Carowan. Quotations below are from that filing.
What he actually pled to
Piper pled guilty to one count of conspiracy to introduce misbranded drugs into interstate commerce with intent to defraud or mislead, in violation of 18 U.S.C. § 371 and 21 U.S.C. §§ 331(a), 353(b)(1), and 333(a)(2). The distinction matters for anyone trying to calibrate exposure from the coverage. The five-year statutory maximum comes from the § 371 conspiracy count; § 333(a)(2) itself carries three years. He was charged by felony Information rather than indictment — a negotiated pre-charge resolution.
His significant other and co-defendant, Mayze Nichols, pled guilty to two counts of introduction of misbranded drugs under 21 U.S.C. §§ 331(a), 333(a)(1), 352, 353(b)(1)(B) and 18 U.S.C. § 2, in a separate case, No. 1:26-cr-00040-RJJ.
The conduct, from the record
Investigators identified a Canadian website in 2024 selling unapproved prescription drugs, mostly peptides, to U.S. customers without prescriptions. The operators sourced product overseas, primarily from China or from U.S.-based warehouses of Chinese suppliers. An organizational chart showed Piper and Nichols responsible for overseeing the company’s U.S. warehouse and fulfilling American orders. Piper was also listed as an owner.
The site carried the expected disclaimers — “For research purposes” and “None of the products or services on this site are to be ingested or used on humans, animals or any therapeutic uses.” It also stated that “tirzepatide has been shown to decrease food intake and modulate fat utilization,” listed side effects contemplating human ingestion including dizziness, stomach issues and possible thyroid tumors, and described the company as “a team of health enthusiasts that advocate for a stronger, healthier world,” offering “third-party tested, pure products designed to give you maximum results.” Products were merchandised under names including Bulk Bro Duo, Hunger Rush, Fountain of Youth and Workout in a Vial.
Agents made multiple undercover purchases. They were never asked to verify research intent and were never asked for a prescription. Two of the vials they received were physically labeled “PRODUCT OF USA.” When the undercover agent asked where products shipped from, the company said it maintained both U.S. and Canadian warehouses, and did not answer a follow-up asking where in the U.S. Piper later told investigators the drugs shipped from China.
The affiliate and “coaching” structure — read this part closely
The site ran an affiliate program in which affiliates promoted products on their personal social media for commissions and supplied customers with dosing information. Piper was one of those affiliates. After the first undercover purchase of semaglutide, the agent emailed Piper about dosing. Piper’s reply, dated July 20, 2024, from “Coach Piper”:
“It’s actually illegal for a research peptide company like [X] to include dosing or reconstitution instructions with their products. However, as a coach for a private company, I can help you out with that. I charge $25 per protocol.”
He then asked whether the agent was currently on semaglutide, at what dose, and what his goal was. The agent said he had never used it and wanted to lose weight. Piper said it was simple, explained he worked for the Canadian site and was also a fitness and pharmacology coach on the side, took $25, and sent a document titled “Research Protocol for Semaglutide.”
That structure — the company stays silent on dosing, a legally separate coaching entity supplies it — is not unique to Piper. It is a recognized workaround in this market. The government did not treat it as a firewall. It treated the email as proof Piper knew the conduct was unlawful, and quoted it back at sentencing as evidence of intent.
Milestone Purity, and the “Premier U.S. Supplier” problem
After a falling out with the Canadian operators, Piper launched www.MilestonePurity.com in October 2024. Milestone advertised “high-quality” products that were “research driven innovations” and “Precision-Crafted,” and promoted “products developed to enhance health and wellness through scientific rigor and natural purity.”
Here is the finding most worth your attention. Milestone never stamped its products “PRODUCT OF USA,” and Piper argued at sentencing that no Milestone customer was defrauded for that reason. The government’s answer, in a footnote: the site described itself as customers’ “Premier U.S. Supplier for Precision-Crafted Research Peptides. With a commitment to quality and transparency” — numerous claims “designed to lead customers to believe they were purchasing products produced in the United States,” while omitting truthful information about the source. Piper had admitted acquiring product by WhatsApp messages to someone named “Emily,” paying via Bitcoin and PayPal to a Chinese email address.
An implied origin claim was treated the same as an express one. “Premier U.S. Supplier” is unremarkable marketing copy that appears on storefronts across this market. In this record it became a misrepresentation supporting a fraud-based guidelines calculation.
Two other findings in the same vein. Milestone claimed all products were tested before sale — which Piper cited as a reason he left the Canadian company — but the analysis posted on the site predated Milestone’s existence by many months. And at checkout, the site instructed customers: “For payment, use ONLY your Order Number . . . in the payment reference section. DO NOT include product names or any additional details in the payment notes.” The government cited that instruction as evidence Piper knew the business was illegal.
Investigators executed a search warrant at the home Piper and Nichols shared, where Milestone was based and merchandise was stored in the basement. Piper gave a full interview. He admitted he owned Milestone, managed sourcing, supplies, graphic design and website oversight, did not know who manufactured the products, never asked customers for prescriptions, required no specific information before fulfilling an order, and had never registered with FDA to manufacture and sell drugs. Bank analysis showed he obtained $218,790.32 across both sites.
The guidelines analysis — the most important part of the case
Because Piper pled to conspiracy, the calculation started at U.S.S.G. § 2X1.1, cross-referenced to § 2N2.1 (unapproved and misbranded drugs), and then — because Piper admitted the offense was committed “with the intent to defraud or mislead” — a second cross-reference under § 2N2.1(c)(1) landed the analysis in § 2B1.1, the fraud table. Offense level in a fraud case is driven by loss.
Then the provision every operator in this space should read. Under § 2B1.1 App. N. 3(E)(v), where items are “falsely represented as approved by a governmental regulatory agency,” or are of such a nature that they should have been subject to regulatory authority, “loss shall include the amount paid for the property, services or goods transferred, rendered, or misrepresented, with no credit provided for the value of those items or services.”
No credit for the value of the goods. The customer’s money is the loss even if the vial contained exactly what the label said. Revenue becomes the number that drives the sentence.
Because loss could not be precisely determined — some customers got what they paid for, others did not, and funds could not be traced to individual purchases — the government used gain as a substitute, citing United States v. Bhutani, 266 F.3d 661 (7th Cir. 2001) and United States v. Milstein, 401 F.3d 53 (2d Cir. 2005). The PSR used the full amount from both sites. The parties agreed to a more conservative estimate of $95,000 to $150,000, which cut two levels to a total offense level of 13.
Piper was scored criminal history category V. That produced the agreed range of 30 to 37 months. The same offense level for a defendant with no criminal history would have produced 12 to 18 months. So the guideline exposure in this case was driven heavily by his record, not by the peptide conduct alone — a point worth keeping in view before treating 21 months as the going rate for this fact pattern. And the 21-month sentence was itself a downward variance from the agreed range, not a fraction of some statutory ceiling.
On the § 3553(a) factors, the government emphasized that the drugs came from unknown, unverified Chinese manufacturers; that even where testing existed it was incomplete and misleading, because the tests examined neither adulterants nor sterility in products designed to be injected; and — notably — that “black-market drug schemes are so serious, even when the substances at issue are not traditional Schedule I and II controlled substances.” The memo also states Piper joined the conspiracy to make easy money and to support his own addiction, while crediting his full confession at the search warrant, his guilty plea without requiring a grand jury presentation, near-daily NA and AA attendance, and an app he built to help people in recovery stay accountable.
So: was this a typical RUO operation?
No — and it is worth being precise about which parts were and were not, because the distinction is where the practical guidance lives.
Not defensible on any theory: vials physically labeled “PRODUCT OF USA” while sourced from China; a checkout instruction telling customers to keep product names out of payment records; a posted testing analysis predating the company’s existence; selling personal dosing protocols for $25 in an email that acknowledges the company cannot lawfully provide them.
Common enough in this market to be worth naming: an affiliate program where promoters discuss dosing; a separate coaching entity supplying protocols the company will not; product copy describing effects and side effects; “Premier U.S. Supplier” positioning; third-party testing representations resting on supplier documentation.
The second list is the one to sit with — not because it describes how this industry generally operates, and not because well-run companies look like this. They do not; the operators I work with do not have these problems. But these practices turn up often enough across the market that the case is worth reading closely, because in this record none of them was charged as a standalone crime and every one of them still mattered. Together they supplied the intent element and the fraud cross-reference that moved the calculation into the loss table.
The lesson is not that every RUO company is one indictment away. Most are not, and a disciplined operation looks nothing like this record. It is that a short list of fixable practices carries far more legal weight than the companies still carrying them tend to realize.
FDA is running the same theory on far thinner facts
On September 1, 2026, FDA posted warning letters dated August 24 to five online peptide sellers: Peak Performance Peptides, Royal Peptides, NuScience Peptides, Peptide Partners, and TXP Innovations dba Tex Peptides.
The Royal Peptides letter is the more instructive document for most operators. FDA said that despite labeling marketing the products “for research use only” and “not for human or animal consumption,” evidence obtained from the website established that the products were intended to be drugs for human use. Alongside the drug claims it cited, FDA pointed to something considerably more mundane: bacteriostatic water marketed together with a peptide guide and a peptide calculator — resources that, in the agency’s words, “collectively provide the means to prepare an injectable drug for human administration.”
Piper needed a stack of aggravating acts to reach a criminal case. FDA needed drug claims plus a product bundle that is widely offered across this market. Different burdens of proof, same underlying argument: the disclaimer loses to everything surrounding it.
The civil front
On August 12, 2026, Eli Lilly filed six federal lawsuits against businesses it accuses of illegally selling retatrutide — four RUO sellers, a med spa and a compounding pharmacy — the first time it has targeted RUO sellers specifically. Lilly’s theory is that sellers falsely market products as research use only when they are intended for human use, and the company says it has referred more than 200 individuals and entities to FDA, DOJ, state attorneys general, law enforcement and licensing boards. Unlike FDA, Lilly is also pressing platforms, payment processors and shipping carriers.
Where the government is steering this
On July 23 and 24, 2026 — the same days Piper was sentenced — FDA’s Pharmacy Compounding Advisory Committee voted to recommend that BPC-157, KPV, TB-500, MOTS-c, Epitalon and Semax be added to the list of bulk substances compounding pharmacies may use, over the unanimous opposition of FDA’s own staff scientists, who cited thin clinical data, batch inconsistency and immunogenicity risk.
Read narrowly, nothing changed. The recommendations are non-binding, require HHS sign-off, and pharmacies cannot compound these substances until formal rulemaking is complete, which could take months or longer. Pharmacists spent the weeks that followed correcting the widespread claim that the vote made these peptides legal to compound. And the six peptides at issue are not the GLP-1 analogs driving the enforcement cases.
But read the vote for direction rather than immediate effect. Several committee members framed their yes votes explicitly as harm reduction — a way to pull consumers away from a market where peptides are bought from overseas sellers as unregulated research chemicals with no physician involved. That is the same concern the government articulated in Piper: unknown Chinese manufacturers, no sterility or adulterant testing, injectable products, no prescriber anywhere in the chain.
The administration is not signaling that peptides should be less available. It is signaling that they should move through the medical pathway — evaluated by a licensed practitioner, dispensed by a regulated pharmacy, with a patient record behind them. The enforcement actions and the compounding vote are two expressions of the same policy preference.
Why the telehealth path is worth evaluating now
None of this makes RUO unlawful per se, and plenty of operators will reasonably decide to stay and tighten up. But it is worth understanding precisely what a telehealth model does to the risk, because it removes categories of exposure rather than managing them. Working down the same list of facts:
- No prescription for prescription drugs → a licensed practitioner evaluates the patient and writes one.
- Research-use framing nobody believes → unnecessary, because human use is the disclosed, lawful purpose.
- Copy describing human effects and side effects → no longer evidence of concealed intent; it is appropriate patient information.
- Affiliates or a side coaching entity supplying dosing → dosing comes from the prescriber, inside a documented patient relationship.
- Testing that examines neither adulterants nor sterility → dispensing runs through a 503A or 503B facility subject to inspection.
- Unknown foreign sourcing → a traceable supply chain with an identifiable manufacturer.
- Implied U.S.-origin marketing → origin is documented rather than suggested.
Most importantly, it takes the case out of the fraud table. The § 2N2.1 cross-reference into § 2B1.1 fired because the offense involved intent to defraud or mislead. That element rests on a gap between what the business says it is doing and what it is actually doing. A telehealth model closes that gap by design — which also means a stray affiliate post or an unguarded support reply stops being evidence of fraud and becomes an ordinary compliance matter.
It is not a trivial lift. Corporate practice of medicine and fee-splitting constraints, a properly papered MSO/PC structure, state-by-state licensure and telehealth modality rules, pharmacy relationships, advertising review, and — for GLP-1s specifically — a clear-eyed read on what may lawfully be compounded, which is its own developing question the PCAC vote does not answer. But these are known structuring problems with known answers, solved once and then maintained. Guaranteeing that nobody in a distributed affiliate network ever sells a dosing protocol is a harder problem, because it never finishes.
What I would do this quarter
- Audit origin claims first, including implied ones. “Premier U.S. Supplier,” “U.S.-based,” domestic imagery, and anything else that suggests domestic production while the product ships from abroad. The government treated the implied claim as actionable.
- Look hard at any separate coaching or protocol entity. If the arrangement exists because the company cannot lawfully provide dosing, assume that rationale will be read as evidence of knowledge rather than as a firewall. Piper put it in writing.
- Verify your COAs are yours. Analysis predating your company’s existence, or belonging to a supplier’s lot rather than yours, is worse than no testing claim at all.
- Remove every payment-obfuscation instruction. Whatever the processor relationship requires, telling customers to keep product names out of payment records reads as consciousness of guilt.
- Understand your revenue as a loss figure. Under App. N. 3(E)(v) there is no credit for the value of the goods. Run your annual gross through the § 2B1.1 table and see where it lands. That number is the honest measure of the exposure.
- Cost out a telehealth conversion. Entity structure, practitioner network, pharmacy partner, state footprint, timeline. Even if you stay where you are, you will have priced the alternative — and a conversion takes months to stand up, so the evaluation is worth doing before you need it.
LumaLex Law advises companies in peptides, compounding, telehealth and other heavily regulated emerging markets, including RUO-to-telehealth conversions and MSO/PC structuring. If you want a candid read on where your operation sits against this record, get in touch.
This article is general information about a public federal proceeding and is not legal advice for any particular situation. Nothing here creates an attorney-client relationship. Facts and quotations are drawn from the United States’ Sentencing Memorandum, United States v. Piper, No. 1:26-cr-00018-RJJ (W.D. Mich. July 8, 2026), ECF No. 20; the sentencing memorandum reflects the government’s positions, and statements attributed to the PSR are as characterized in that filing.
