|Tulip Lab is a pharmaceutical manufacturer and distributor located in Mumbai, India.
Tulip Lab came to light as being directly related to the spamming activities of the sponsor organization known as GenBucks during a series of investigations starting in October of 2007. In a report by the BBC's Simon Cox for his BBC4 radio show "The Investigation", he uncovered a direct link between a spam message he had received promoting "Manster" and Tulip Lab. 
On October 6th, 2008, Shane Atkinson and his brother Lance -- two operators of the GenBucks and SanCash (also known as AffKing) affiliate programs -- were charged with promoting products manufactured and distributed by Tulip Lab via illegal Spam. Evidence was very well documented in court documents.
 Evidence of Links to Genbucks, and to SanCash / AffKing
Both the BBC's Simon Cox, and the operator of SpamInMyInBox, Hemryk Uffe-Jensen, had discovered a direct link between inbound spam for "Elite Herbal" and ip addresses located in Mumbai, India and Christchurch, New Zealand.
From a transcript of the BBC4 radio show:
We weren't the only ones trying to track down the people sending out the spam emails. Hemryk Uffe-Jensen, an IT consultant from Denmark, was also on their trail. He was so sick of the junk email from Elite Herbal, he decided to turn the tables on them, and set a trap. He'd ordered the same pills as me, but he'd put in a piece of computer code in the order form. This meant he could see the location and IP address of the computers that were processing his order. **** Simon Cox (SC): When you got those IP addresses, what did that help you to do then? Hemryk Uffe-Jensen (HJ): Well one of them turned out to be, uh, a company called Tulip Labs in India, which I looked up and found out was on the outside looking like quite a big and well-established company. (SC): And when you looked up Tulip Labs, what were they actually doing, what were they -- what do they actually produce? (HJ): They produce herbal products which was this particular spam, with Elite Herbal, that was penis enlargement and such things they were selling. So it fitted very well with the products. **** Hemryk wanted to know why Tulip Labs was sending out products for spammers. He sent the company numerous emails, but didn't get any reply.
As we'll see later, Mr. Cox did contact Tulip Lab directly, and -- likely owing to his pedigree with the BBC -- he managed to actually talk to someone.
 Fake Herbal Products
It was documented in the BBC report, but also elsewhere, that products purchased and received via spamvertised sites for products such as VPXL, Manster, ManXL, PowerEnlarge, etc. all contain no effective ingredient whatsoever, and do not offer the so-called "remedies" they claim. In the web transcript of the BBC4 investigation, Simon Cox had a nutritionist analyse the products he received from India after purchasing them on a spammed website promoting "Manster":
Two weeks after I placed my order a brown envelope arrived from India. Inside was a bottle of Manster pills and the promise of a month's worth of enhanced sexual performance - although there is no mention of penis enlargement. I sent the list of herbal ingredients to David Schardt, a senior Nutritionist at the Center for Science in the Public Interest in Washington DC. He couldn't find any evidence to show that most of the ingredients would have any effect. What had cost me £35, he said, I could pick up for 50p in India.
We have seen in the past year or so (2007 - 2008) that any attempt to publicly expose the ties between the inbound spam for products such as VPXL or illegal pharmacy sites such as Canadian Healthcare have resulted in instantaneous litigation on behalf of Tulip Labs, often served ex parte within India and in no other country. The operator of a blog which exposed these links known as SpamInMyInBox was served an injunction without ever being notified, and was threatened (again, only in India) with further legal action should he fail to remove any claims outlining ties between Tulip Lab and any spamming activity.
It is unknown whether BBC investigative reporter Simon Cox was also served with any such injunction. There is no official archive of the BBC4 show which investigated Tulip Lab, Genbucks and a spammer located in New Zealand known as Shane Atkinson.
 Partial Transcript
Here is a partial transcript of a phonecall made by Simon Cox to the Tulip Lab offices in Mumbai. This transcript is written verbatim based on the audio of the BBC4 radio show "The Investigation" dating from Dec. 13th, 2007.
He: Thank you for calling. This is Alwyn, how may I assist you? Simon Cox (SC): Hi, I just wanted to check, um, I'm trying to check an order I placed. Is that, is this Tulip Labs? Because I think I placed the order with them. It was for a bottle of Manster. He: Uh... Sir, we have two departments, one is, uh, Tulip Lab and one is Tulip Edge. (SC): So is this coming from... Is this Elite Herbal? 'Cos that was when I got it from... the website was Elite Herbal was that...? He: Rrright... right (SC): Is that you? Or is that someone else? He: Uh, no it's, ah, we have u-usually we have uh for each product we have many websites, sir. (SC): Right He: So yes. So we have nearly 35 to 40 products which we sell, and we have different websites for each product. (SC): Right. 'Cos the... so... Just so... I'm slightly confused, because the phone number was GenBucks. Is that part of it as well? Is that another website? He: Uh... Sir, that is one of our departments, sir. (SC): Right. Okay. Alright. Okay. Well thank you. Hopefully it'll get here anyway. He: Uhhh... okay sir. (SC): Alright. Thanks for your help. Alright. Bye bye. He: You're welcome sir. Thank you for calling and you have a great day. **** So Tulip Lab and GenBucks are closely linked, possibly even the same company. We contacted Tulip Lab in Mumbai, requesting an interview. After several phonecalls and emails, they sent us this reply: **** We are a manufacturer of herbal food supplements, and supply our products to various marketers and distributors around the world. We play no role in the communications with the end user customer. ****
 Attempts To Conceal Evidence
Within a week of the BBC4 radio show airing, several very rapid changes took place across multiple websites which were used as evidence for both the BBC show and the SpamInMyInBox blog. Websites for independent designers which showed samples of design work for Genbucks, Tulip Labs and several of their spamvertised properties were suddenly edited.
Members of numerous forums who represented Genbucks or SanCash were suddenly nowhere to be found, and suddenly chose to communicate using only off-forum or offline means. Notably, "azzy", a representative of SanCash who once posted very publicly on forums such as bulkerforum.biz promoting products now known to be tied to Tulip Lab was suddenly extremely difficult to find. Numerous members of that forum in particular wondered what was going on with SanCash. All of this was within a week or so of the raid on several properties in Christchurch, New Zealand apparently directly related to the spamming activities of Shane Atkinson. Those raids took place one week after the airing of the BBC's investigative report.
From a thread posted on Bulkerforum.biz, which has been quoted on the anti-spam blog IKillSpammers
TOPIC: SANCASH.. What's going on ? mic141414 Joined: 12 Jul 2007 Posts: 37 Posted: Thu Dec 20, 2007 8:19 am Post subject: SANCASH.. What's going on ? they are offline .. been like that the last 3-4 days. Commissions NOT paid this week. Anyone has news on that ?? I am a little worried for my $$ thanks
And in a second thread:
ubuntu Joined: 06 Feb 2007 Posts: 12 Posted: Thu Dec 20, 2007 10:26 am Post subject: not sure if this is sancash this is related to this audition.. and hmm.. looks like GB... http://www.bbc.co.uk/radio4/theinvestigation/pip/uvboh/ 19:11, 22 October 2008 (CEST)19:11, 22 October 2008 (CEST)19:11, 22 October 2008 (CEST)19:11, 22 October 2008 (CEST)19:11, 22 October 2008 (CEST)19:11, 22 October 2008 (CEST)19:11, 22 October 2008 (CEST)19:11, 22 October 2008 (CEST)19:11, 22 October 2008 (CEST)19:11, 22 October 2008 (CEST) jhood Joined: 23 Oct 2006 Posts: 151 Posted: Thu Dec 20, 2007 11:51 am Post subject: thanks for link ubuntu.. eliteherbal/manster IS SanCash 19:11, 22 October 2008 (CEST)19:11, 22 October 2008 (CEST)19:11, 22 October 2008 (CEST)19:11, 22 October 2008 (CEST)19:11, 22 October 2008 (CEST)19:11, 22 October 2008 (CEST)19:11, 22 October 2008 (CEST)19:11, 22 October 2008 (CEST)19:11, 22 October 2008 (CEST)19:11, 22 October 2008 (CEST) icanspam Joined: 10 Aug 2007 Posts: 52 Posted: Thu Dec 20, 2007 2:22 pm Post subject: SA? Shane Atkinson, bro. 19:11, 22 October 2008 (CEST)19:11, 22 October 2008 (CEST)19:11, 22 October 2008 (CEST)19:11, 22 October 2008 (CEST)19:11, 22 October 2008 (CEST)19:11, 22 October 2008 (CEST)19:11, 22 October 2008 (CEST)19:11, 22 October 2008 (CEST)19:11, 22 October 2008 (CEST)19:11, 22 October 2008 (CEST) mail4spart Joined: 15 Sep 2006 Posts: 33 Posted: Thu Dec 20, 2007 5:18 pm Post subject: I know Shane is a straight up guy and doesnt deserve all this heat. I hope he can survive this like he did last time he came under a lot of heat before him and his brother. He has been running a smart business for a long time and looks after his people and if he has to shut down the biz there will be many affiliates effected and unpaid.
It was discovered later, when charges were laid against Shane and Lance Atkinson, that they had very rapidly switched the SanCash program over to "AffKing", literally hours after the BBC report aired.
 New Zealand Raid
On Dec. 19th, 2008, a New Zealand news site posted a story about a raid which took place by the New Zealand Department of Internal Affairs on properties in Christchurch, New Zealand related to "claims that a Christchurch business organised affiliates around the world to send spam on its behalf offering pharmaceutical products and watches." 
As we have seen in multiple postings on behalf of SanCash, made by username "azzy" on forums such as bulkerforum.biz, SanCash promoted precisely these products.
This led to court charges filed on October 6th, 2008 against Lance Atkinson and his brother Shane on behalf of the New Zealand Department of Internal Affairs.
Its Statement of Claim alleges that company directors, Shane Atkinson of Christchurch, his brother Lance Atkinson of Pelican Waters in Queensland and Roland Smits, a courier of Christchurch, were involved in sending over 2 million emails to New Zealand addresses alone between September 5 and December 31 2007. The trio allegedly earned sales commissions of more than $US2 million from their global operation. The emails marketed Herbal King, Elite Herbal and Express Herbal-branded pharmaceutical products, manufactured and shipped by Tulip Lab of India, through a business known as the Genbucks Affiliate Programme. This business was operated by Genbucks Ltd, a company incorporated in the Republic of Mauritius.
 US FTC and New Zealand Law Enforcement Charges
On Oct. 13th, 2008, several charges against Lance Atkinson, Shane Atkinson and Jody Michael Smith, as well as several companies under their control, were filed in US Federal court by the US Federal Trade Commission regarding the illegal promotion of pharmaceutical and other products. The court documents outlined that the products promoted by the Atkinsons' SanCash and AffKing affiliate program via illegally-sent spam were either fake or dangerous, and violated US FDA regulations. Among the claims made in the court documents are:
The Affking operation promotes an "herbal" male enhancement pill that does not work as claimed and is falsely represented to be "100% safe and natural." The product is sold on Web sites that often identify the product as "VPXL," although other names for the product are used. (PX 1 ¶ 31, Att. R.)12 The pills cost $59.95 plus $17.95 shipping and handling. (Id. ¶ 32.) An undercover VPXL purchase was received from China. (Id. ¶ 34, Att. T.) The Web sites falsely claim that the product is "100% natural with no known side effects" and "a 100% safe and natural herbal formula[.]" (PX 1 ¶ 31, Att. R at p. 3,4.) In fact, the VPXL product that the FTC purchased undercover was tested by the FDA's Division of Pharmaceutical Analysis, and it was found to contain sildenafil, the active ingredient in Viagra. (PX 17 ¶¶ 2-4, Att. A.)13 According to testimony submitted by the FTC from a urology expert, a supplement containing sildenafil cannot be considered 100% safe and could cause significant side effects in certain individuals, even in small doses. (PX 18 ¶¶ 6-7,15-22.)
The operation falsely claims to be a bona fide U.S. licensed pharmacy
In fact, Defendants do not operate a pharmacy licensed in the United States. Pharmacies in the U.S. are licensed by individual states.
The operation falsely claims to sell FDA approved drugs
The operation makes false security claims
 [ pdf ]
Although none of the publicly-released court documents explicitly mention Tulip Lab, both independent and law enforcement investigations in numerous countries has pointed to Tulip Lab being the manufacturer and distributor of the products that SanCash and AffKing were promoting. Sealed court documents in the New Zealand case apparently make a very specific reference to Tulip Lab, which was summarized in the press conference of October 13th, 2008 and reported by numerous New Zealand media outlets:
The officials further said that Atkinson allegedly operated a botnet consisting of 35,000 computers that could send 10 Billion spam-mails per day. Moreover, Internal Affairs alleges that the e-mails advertised pharmaceutical products like Elite Herbal, Express Herbal and Herbal King manufactured by Tulip Lab of India and sold through an entrepreneurial venture named the Genbucks Affiliate Programme.
The department alleges Shane Atkinson was co-manager of the Genbucks Affiliate Program and that Lance Atkinson, trading under the name of Sancash, recruited and paid spammers to market Genbucks products, adult sex toys and replica watches. It said Roland Smits registered the domain names used in the Sancash spam e-mails and created alternative subject lines used to avoid interception by Internet service providers' spam filtering software. The e-mails marketed pharmaceutical products manufactured and shipped by Tulip Lab of India.
Several press releases at the time these charges were announced by both New Zealand law enforcement and the FTC also make specific mention that Tulip Lab was the party responsible for manufacturing and distributing these fake and potentially harmful products.
Internal Affairs, in its statement of claim filed in the High Court at Christchurch yesterday, alleges the emails marketed pharmaceutical products Herbal King, Elite Herbal and Express Herbal which were manufactured and shipped by Tulip Lab of India, through a business known as the Genbucks Affiliate Programme.
 Further Reading
FTC v. Atkinson (et al): Memorandum Supporting Plaintiff's ex parte Motion for a Temporary Restraining Order with Asset Freeze, Other Equitable Relief, and Order to Show Cause Why a Preliminary Injunction Should not Issue
IKillSpammers: On The Trail Of SanCash And [so-called Infinity Secure]