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UNITED STATES OF AMERICA

FEDERAL TRADE COMMISSION

OFFICE OF ADMINISTRATIVE LAW JUDGES

________________________________

In the Matter of

JASON SCOTT, DVM,

Docket No.

Appellant.

________________________________

9449

ORAL ARGUMENT

DATE:

Wednesday, July 22, 2026

TIME:

11:01 a.m.

BEFORE:

Jay L. Himes, Administrative Law Judge

LOCATION:

Remote Proceeding

600 Pennsylvania Avenue, NW

Washington, DC 20580

REPORTED BY:

Helen Tadesse

JOB NO.:

8343288

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A P P E A R A N C E S

ON BEHALF OF APPELLANT JASON SCOTT, DVM:

JOSEPH DE ANGELIS, ESQUIRE

Brewster & De Angelis, PLLC

2617 East 21st Street

Tulsa, OK 74114

jcdeangelis@brewsterlaw.com

(918) 742-2021

ON BEHALF OF HORSERACING INTEGRITY & WELFARE UNIT:

ALLISON FARRELL, ESQUIRE

Horseracing Integrity & Welfare Unit

4801 Main Street, Suite 350

Kansas City, MO 64112

afarrell@hiwu.org

(816) 285-1425

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A P P E A R A N C E S (Cont'd)

ON BEHALF OF HORSERACING INTEGRITY AND SAFETY

AUTHORITY:

SAMUEL REINHARDT, ESQUIRE

Horseracing Integrity and Safety Authority

201 East Main Street, Suite 340

Lexington, KY 40507

samuel.reinhardt@hisaus.org

(877) 513-2919

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A P P E A R A N C E S (Cont'd)

ALSO PRESENT:

Robert Silverstein, Litigation Attorney, Office

of General Counsel, Federal Trade Commission (by

videoconference)

Susel Koepke, Attorney Advisor, Federal Trade

Commission (by videoconference)

Dana Gross, Legal Administration, Federal Trade

Commission (by videoconference)

LaShaon Asberry-Beach, Legal Administration,

Federal Trade Commission (by videoconference)

Michael Alonzo, Legal Intern, Federal Trade

Commission (by videoconference)

Heather Prescott, Paralegal, Brewster &

De Angelis, PLLC (by videoconference)

Jason Scott, DVM, Appellant (by videoconference)

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E X H I B I T S

NO.

DESCRIPTION

(None marked.)

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ID/EVD

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P R O C E E D I N G S

THE REPORTER:

and we're on the record, sir.

THE COURT:

The time is 11:01 a.m.,

Good morning to everybody.

As many of you know, I'm Judge Himes and I'm the ALJ

at the Federal Trade Commission assigned to this case,

Matter of Scott, Docket Number four -- I'm sorry --

9449.

as part of the merits briefing in the case.

the parties to argue whether the AMP -- and I'll use

the abbreviation -- found in the February 20, 2025,

search of Dr. Scott's SUV can properly be classified

as a S0 banned substance under the AD -- AMDC [sic]

rules, specifically here, Rule 4111.

This is the oral argument that I have asked for

I asked

So let me take the appearances of the

parties.

attending with you, either in the same room or

elsewhere?

Dr. Scott.

Will you please identify yourself and anyone

I will start with the appellant,

MR. DE ANGELIS:

Angelis for Dr. Scott.

Heather Prescott.

Your Honor, Joseph De

With me is my paralegal,

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THE COURT:

And for the Authority?

MS. FARRELL:

Okay.

Yes.

Good morning, Your

Honor.

And I note that General Counsel of HISA, Samuel

Reinhardt, is also present on this call remotely.

Allison Farrell on behalf of the Authority.

THE COURT:

Okay, good.

And again, you

are appearing for the Authority, although strictly

speaking, you are a HIWU person; right?

MS. FARRELL:

THE COURT:

argument is being conducted via video.

not publicly identified a feed for members of the

public to attend, the proceeding is not confidential.

So if by some stretch of the imagination, some member

of the public has found the link, I don't think so

because I don't see anybody, but they could come on,

and just be attentive to that.

Correct, Your Honor.

Okay.

Obviously, this

Although we've

I do not think there will be any issue

of confidentiality raised in the argument, but if

either counsel thinks something is or was or is about

to be confidential, then, you know, wave your hands,

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get my attention, and we will take whatever steps are

necessary to implement that.

unlikely to me.

But that sounds pretty

The FTC's OALJ office is managing the

logistics of this hearing.

is being transcribed by a court reporter.

ask the court reporter to identify herself, please?

As you see, the argument

THE REPORTER:

I'm Helen Tadesse.

Yes.

And may I

Good morning, sir.

I'm a court reporter.

THE COURT:

And once the transcript is finalized,

Thank you.

it will be filed on the docket in this case.

Finally, we have members of the FTC's

Office of Administrative Law Judges attending as well

here today, and another member of the FTC staff.

I will only summarize the logistics

because we've already sent you instructions and

procedures, so I can just do this very briefly.

those individuals who are authorized to speak during

the argument can do so via the Teams link that we've

sent.

Only

If you are counsel who are speaking

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today, you must have your video on at all times, and

your audio on only when you are speaking.

before speaking, Counsel, identify yourself for the

court reporter, just so we have that as clear as can

be.

Please,

Now, I will also only summarize the

review proceedings here since I'm sure you're very

familiar.

vehicle at Sunland Park Racetrack in New Mexico.

In February 2025, HIWU searched Dr. Scott's

The HIWU investigators found two banned

substances, AMP and Sarapin, both of which HIWU and

now the Horseracing Integrity and Safety Authority on

this review contend are banned substances.

HIWU charged Dr. Scott with two

possession violations.

arbitration, the arbitrator upheld both charges.

Dr. Scott began this review proceeding to have the two

violations overturned.

concerns only the possession of AMP.

And in the ensuing

Today's argument, however,

Now, AMP is not expressly identified in

the ADMC rules as a banned substance.

argues that it is covered under the catchall of ADMC

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Instead, HIWU

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Rule, which I previously mentioned, 4111.

rule captures non-identified substances that meet

certain criteria delineated in the rule.

so-called S0 classification of banned substances.

And that

This is the

And even if the rule criteria are met,

there are two carve-outs that can in effect negate

coverage.

called AMDUCA, which is a federal statute; and

something else called GFI number 651 [sic], which is

an FDA, essentially, policy statement.

And those carve-outs relate to something

So we're here today to consider whether

AMP is indeed covered under Rule 4111.

before we proceed?

for the Authority first.

Good.

Any questions

I will hear from counsel

MS. FARRELL:

Allison Farrell on behalf of the Authority.

really quick before I start, I don't want to be

informal, but I do want to sort of give a heads-up

that we've had some pretty catastrophic flooding and

I'm not in my office today.

so I wanted to let you know there may be a dog barking

in the background.

Thank you, Your Honor.

And

I can't get there.

I apologize in advance.

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So with

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that said --

THE COURT:

wallpaper up, so it's all official.

But you do have the HIWU

MS. FARRELL:

It's -- it's very

official.

THE COURT:

MS. FARRELL:

Okay.

So go right ahead.

Thank you.

So I would

like to reserve five minutes for a response as allowed

for under your order, Your Honor.

aware, there's three requirements that have to be met

in order for AMP to be deemed a banned substance.

And as we're all

I'll quickly run through those three

requirements.

requirement number 1, both sides agree that AMP is not

dealt with by Rules 4112 through 4117, as it's not

listed on the prohibited list.

of criteria number 1.

The first one, both sides --

So it checks the box

So requirement number two, it means --

it says there can be no current approval by any

governmental regulatory health authority for

veterinary or human use.

give rise to a dispute between the parties.

Now, this requirement does

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look to Dr. Benson's report, in the 1970s, the FDA

withdrew AMP from approval, as it was deemed neither

safe nor effective as a vasodilator.

AMP has been expressly rejected by the

FDA, and has been that way for 50 years.

opposite of having current approval by any

governmental regulatory authority.

argued --

THE COURT:

MS. FARRELL:

THE COURT:

MS. FARRELL:

This is the

But as was

In the United States.

Correct.

Sorry.

Yes.

Go ahead.

And as -- oh, yeah.

was just going to get to that point.

the respondent argued -- the appellant here argued,

"But wait, AMP is approved by the Australian drug

regulators.

the approval of any governmental regulatory

authority."

As argued below,

So it satisfies the requirement of having

The Authority's position is that the

fact that AMP is approved by Australian regulators is

irrelevant and in an absurd interpretation of a U.S.

federal regulation.

U.S. law applies in the U.S., not

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Australian law.

And more to the point --

THE COURT:

MS. FARRELL:

THE COURT:

Can I ask a question?

Sure.

What is your best case for

that proposition?

MS. FARRELL:

So my next point is that

the bulk drug application by Wedgewood Pharmacy to the

FDA, seeking to have AMP listed on the list of bulk

drug substances approved for compounding, which was

ultimately rejected by the FDA, explicitly states that

the Australian version of AMP was not available in the

U.S.

That's at Appeal Book 5391.

And then Dr. --

THE COURT:

I'm going to stop you there

on Wedgewood.

bulk drug list was in 2024, and it wasn't rejected

until after Dr. Scott's search -- of the search of

Dr. Scott's vehicle.

But the Wedgewood nomination to the

MS. FARRELL:

THE COURT:

Correct.

If understanding how all of

this stuff works, while the nomination was pending

review, the substance, as a compounded substance,

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could be used in the U.S.

Am I wrong about that?

MS. FARRELL:

there's also an and.

You are correct, but

THE COURT:

Okay.

MS. FARRELL:

AMP -- yes.

And so AMP

could -- it was considered -- you could use AMP as

long as it was under review, but whoever compounded

the AMP and used it, had to follow the further

requirements of GFI 256.

position that the appellant did not comport with the

additional requirements necessary to get the benefit

of that carve-out.

And it's the Authority's

THE COURT:

Or at least that wasn't

proven in this case.

proof that GFI 256 was satisfied in this case?

Is that fair?

MS. FARRELL:

THE COURT:

There was no

Yes.

Okay.

I'm sorry.

interrupted you with the Wedgewood diversion, but I

apologize.

Go right ahead.

MS. FARRELL:

understand.

argument, I think.

No.

I mean, I

That's basically the heart of this

And I was going to get to it when

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I got down to the exceptions, but we just sort of

skipped a little bit ahead.

THE COURT:

Well, let me ask another

question.

I'm sorry -- in requirement 2, should implicitly

assume that it refers to U.S. veterinary authority

approval; correct?

You say that the regulation -- or the rule,

MS. FARRELL:

THE COURT:

Yes.

Do you not sense a tension

between that assertion and what the Authority said

during the comment period when the rules were under

consideration?

MS. FARRELL:

I'm not -- I don't know

exactly what you're referring to.

THE COURT:

Susel, you can share screen, yes?

MS. KOEPKE:

Yes.

THE COURT:

Can you bring up page 5018

Okay.

from the appeal book?

MS. KOEPKE:

Yes.

THE COURT:

Oh, boy.

bigger?

Never mind.

Can you make that

I'll -- oh, you can.

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see.

I think you have to scroll it down a little bit.

Yes.

There is a comment on the SO -- I'm sorry, S0

classification right in the middle of the page right

now.

You see where I am, Ms. Farrell?

MS. FARRELL:

THE COURT:

Yes.

And if you look at the

response, the last sentence, "This designation can be

revised based on evolving use as recognized by

international regulators, colleges of veterinary

medicine, and individual board-certified specialists."

You see where I've read?

MS. FARRELL:

THE COURT:

Yes, Your Honor.

Okay.

That's the tension

that I'm referring to.

guess it's kind of unfair because you weren't aware of

this.

Do you have any answer?

Is that right?

MS. FARRELL:

I just wasn't sure

exactly what you were referring to when you were

referring to --

THE COURT:

MS. FARRELL:

Oh, okay.

So I think, you know, my

response to this would be -- the Authority's response

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would be, yes, the designation can be revised on

evolving use as recognized by international

regulators, but that is in conflict with the GFI 256

requirements that exist under the GFI 256 enforcement

discretion.

THE COURT:

But that's a carve-out.

You don't even get to GFI 256 unless you can get the

substance under, you know, requirement ii.

to get it there first, and then you have to worry

about whether or not the carve-out for GFI 256

applies.

You've got

Am I wrong?

MS. FARRELL:

No.

I mean, you have

to --

THE COURT:

Do you agree you have the

burden of showing that the substance is banned under

the basic three requirements in 4111; yes?

MS. FARRELL:

THE COURT:

Yes.

And if you can get it in

there, then there are carve-outs.

would agree that Dr. Scott has the burden of showing

the applicability of either one of the two carve-outs;

right?

And I assume you

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MS. FARRELL:

THE COURT:

MS. FARRELL:

THE COURT:

Yes.

Because it's an exception.

Correct.

You want to get out from

under the basic rule.

So your problem is getting it into sub 2 to begin

with.

Your burden is the exception.

MS. FARRELL:

Well, it's the

Authority's position that we would look to U.S. law

for determining whether and how to interpret -- how to

interpret a U.S. federal regulation.

Authority's position with respect to this rule.

And that's the

I mean, if the ALJ decides to revise

that based on recognition of the Australian

international regulatory regime, that is certainly

your purview.

we're going to be looking to U.S. law to interpret our

own federal regs.

But it is the Authority's position that

THE COURT:

I can't accept the risk of

revising anything these days.

there other AMP cases pending?

MS. FARRELL:

Let me ask this.

Are

I'm not aware of any that

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are pending.

There is one that resolved in 2024.

THE COURT:

And am I right that prior

to this case, neither the Authority nor HIWU had

issued any policy statement, enforcement statement,

interpretive understanding, that said subpart 2

relates to U.S. veterinary approval?

MS. FARRELL:

I'm not aware of any such

alert, per se, but I couldn't swear under oath that it

does or does not exist.

I'm not aware of any.

THE COURT:

Fair enough.

Okay.

I know

you haven't touched on sub 3, but I can't resist

asking.

matter here -- but how something could satisfy sub 2

and not satisfy sub 3?

question.

Can you explain to me -- maybe it doesn't

I agree.

This is a hard

MS. FARRELL:

I would have to -- I

would -- I'd like to consult with our expert on this

point, Your Honor, but I think that I see your point.

THE COURT:

You can certainly bow off.

One of the concerns, though, is that part 3 has

language of universal acceptance.

know, that isn't even limited to the U.S.

It doesn't -- you

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MS. FARRELL:

Not by the text of the

rule -- of the requirement, no.

THE COURT:

Okay.

All right.

I think

your ten minutes is up, but do you want to say

anything more?

I think this is important.

MS. FARRELL:

I don't want to cut people off because

I mean, I did have just a

bit about requirement number 3.

the expert evidence where Dr. Benson, you know, said

that there's no literature or research existing to

support the use of AMP to treat or prevent tying up.

And just to highlight

So not only is it not universally

recognized as not having a valid veterinary use for

rhabdomyolysis, it's not recognized at all.

importantly, Dr. Benson -- you know, we don't even get

to the AMDUCA exceptions because there are FDA

approved alternatives for treatment of tying up.

And then,

As Dr. Benson's evidence, you know,

came in, dantrolene, acepromazine, diet changes,

exercise changes -- there are plenty of -- there are

FDA approved drugs that can be used to treat

rhabdomyolysis, rather than just going straight to a

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compounded drug that has -- there's no research or

report supporting the treatment.

THE COURT:

MS. FARRELL:

And I'm just scanning

here really quickly.

Okay.

THE COURT:

You've got reserve time.

recognize it.

MS. FARRELL:

Okay.

That's fine.

can, I'll reserve my five minutes to respond.

you, Your Honor.

THE COURT:

Mr. De Angelis?

MR. DE ANGELIS:

If I

Thank

Okay.

Yes, Your Honor.

I'm

going to -- just as a preliminary note, I'm just going

to refer to AMP as AMP, just because that's how we

talk about it.

THE COURT:

Good, very good.

Good

start.

MR. DE ANGELIS:

So I think that the

problem here is sort of the underlying theme of our

entire appeal, which is that the rules are being

applied, I think, to circumvent the rulemaking and

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revision process that it -- they're interpreting rules

broadly to avoid actually having to justify policy

decisions through the proper process under the statute

and regulations.

But I think that --

THE COURT:

But actually, here, they're

interpreting the rule narrowly.

MR. DE ANGELIS:

Yeah, they are.

And

in doing so, I think they've departed from their --

the explanations they provided in the rulemaking

process.

correct that AMP is not a banned substance because it

cannot be categorically -- it categorically cannot

meet all three criteria for an S0 prohibited

substance.

But I think that you're right.

You're

That language says that it has no

current approval by any governmental regulatory health

authority for veterinary or human use.

the record shows at least two approvals, one by the

FDA and one by Australia.

THE COURT:

withdrawn ages ago, so that doesn't count.

As you noted,

The -Well, the FDA approval was

MR. DE ANGELIS:

Right.

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So what

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I'm -- but the approval I'm referring to is the

guidance in GFI 256 that permits the compounding of

bulk substances when an application is under review.

Both experts agreed that this was a

permission to use it in veterinary medicine.

whatever extent an FDA approval is required, the FDA's

guidance that provides that you can compound these

substances while a petition is pending -- an

application is pending -- means that they were

approved for use for that limited purpose.

THE COURT:

So to

Can I ask a question on

that?

MR. DE ANGELIS:

THE COURT:

Okay.

Sure.

So you've got this

kind of review period.

the Wedgewood nomination.

the evidence, didn't buy his stuff from Wedgewood; did

he?

Ultimately, the FDA rejects

Dr. Scott, if I understand

MR. DE ANGELIS:

No.

There were

several applications for AMP under that docket number.

We didn't put all of them into the record.

put in one because it would have been -- I think there

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were about a hundred applications for AMP.

Wedgewood one was, I think, the principal one.

were a lot of tack-ons under that docket number.

THE COURT:

And the

There

Well, if I -- again, if I

understand the record, the AMP that was seized had a

label that said Pharmaco Equine; right?

MR. DE ANGELIS:

THE COURT:

Yes.

And did Pharmaco Equine put

in a nomination?

MR. DE ANGELIS:

putting in a nomination is required in order to

compound it.

I don't think that

I believe this -THE COURT:

Well, I'm just asking.

Okay.

MR. DE ANGELIS:

Yeah.

But I'm -- I

did not find an application, but I can't confirm one

way or the other that it didn't exist.

application that was most recent when we got the

exhibits.

We grabbed the

I just made that one because -THE COURT:

Did you say there were

about a hundred applications not in the record?

they before or after Wedgewood?

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Were

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MR. DE ANGELIS:

If we -- I believe

some were before or some were after.

the docket number for the FDA to look at.

numerous --

THE COURT:

I could give you

There were

But that to me is a pretty

shocking omission if there's some were before.

Because if you are telling me -- and I think there is

some agreement on this -- that while one of these

nominations is pending, it's okay to use the stuff.

If there were earlier ones, it would have extended

backwards to benefit Dr. Scott.

understand how you could possibly leave those out of

the record.

MR. DE ANGELIS:

And I don't

We didn't think that

it was necessary because it's the -- we wanted an

application where it was clear that it would have

applied during the period of the search.

picked -- we picked the one that had the date range

that just showed that --

THE COURT:

And so we

Do you know anything about

Pharmaco -- Equine Pharmaco?

MR. DE ANGELIS:

Equine Pharmaco?

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THE COURT:

MR. DE ANGELIS:

Yeah.

Yeah, somewhat.

They're a distributor of compounded medications that

compile and source these substances of AMP among

others.

THE COURT:

Where is that in the

record?

MR. DE ANGELIS:

THE COURT:

It's not.

We --

Then how do you know it to

represent it to me?

MR. DE ANGELIS:

I reached out to the

distributor when I was trying to obtain a copy of the

label, and they wouldn't give it to us.

THE COURT:

for them, in other words?

You found a phone number

MR. DE ANGELIS:

for the contact that Dr. Scott gave me, and he

wouldn't talk to me.

nomination had been rejected, and he wouldn't talk to

me about it.

I found a phone number

At this point, the FDA's

THE COURT:

Was that Wedgewood or

Equine Pharmaco?

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MR. DE ANGELIS:

I can't remember his

name.

communications and supplement that for you if you

want, but it --

I can go -- I can look back at my

THE COURT:

None of that's in the

record at this point.

MR. DE ANGELIS:

to answer your question.

THE COURT:

MR. DE ANGELIS:

THE COURT:

It's not, but I want

Yeah, sure.

Yeah.

But I don't see anything

public about Equine Pharmaco.

MR. DE ANGELIS:

I -- we just didn't

look into that.

in our view, because the text of the rules are for the

substance.

the sourcing of the medication, I feel like the FDA

would have started an action.

these aren't, you know, small -- this isn't like a

small organization, but I -- there was just no issue

raised with that.

I mean, it wasn't really important,

If there was an issue that was raised with

THE COURT:

My understanding is

It doesn't have a website

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Page 28

that I can find.

MR. DE ANGELIS:

Well, I don't want to

get too off-topic.

wasn't -- we didn't go down that road because we

didn't think that it was pertinent to the issues in

the case.

raised by HISA or HIWU about the source of the

medication.

We just thought that it

And there wasn't an issue that was being

It was just whether AMP was banned.

That's what their notice said.

a banned substance.

was a banned substance.

argument until six months later in their brief in

chief.

were investigating the matter as if we just needed to

defend whether AMP categorically is a banned

substance, and we took that approach.

They just said AMP is

They didn't say the AMP you found

They didn't make that

So we were approaching this during -- when we

THE COURT:

Is it possible to

distribute AMP without violating federal law?

MR. DE ANGELIS:

THE COURT:

MR. DE ANGELIS:

Yes.

Yes?

And yeah, GFI

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256 -- well, so GFI 256, by its terms, says that it's

a technical violation of federal law to compound bulk

substances.

discretion to say that if you comply with certain

requirements, we're not going to go after you.

But they exercise their enforcement

And that's been -- my understanding is

you can take that to the bank.

compliance, you're not going to get in trouble with

the FDA, and the FDA has exclusive jurisdiction over

that question.

You can show

So that's -- and to answer your

question, it's -- I think that the GFI 256 says, yes,

it's a technical violation, but it's not an enforced

violation.

THE COURT:

MR. DE ANGELIS:

Okay.

So I want to talk

about the Australia approval because I think that this

is probably the easier question.

think it's consistently interpreted by the Supreme

Court to mean one or some indiscriminately of whatever

kind instead of referencing a subset.

cases for you.

The word "any," I

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And I got two

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The first is United States vs.

Gonzales.

rejected the argument that "any" other term of

imprisonment in a federal sentencing statute meant

"any" other federal term of imprisonment, and

concluded that it also reached state terms of

imprisonment.

It's 520 U.S. 1, which specifically

And that holding was reaffirmed in

Ali -- well, that reading was reaffirmed in Ali v.

Federal Bureau of Prisons.

said -- that rejected the argument that "any" other

law enforcement officer includes only law enforcement

officers acting in a customs or excise capacity.

It's 552 U.S. 214.

That

The lesson from both these cases is

that when the word "any" is used, and wants you to

refer to a specific subset, it defines that subset in

the terms of the regulation rather than that you can't

read in a subset of "any" unless the language requires

that.

I also think that this -- that HISA's

argument -THE COURT:

Did Dr. Scott rely on the

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July 22, 2026

Page 31

Australian approval in securing AMP in his practice?

MR. DE ANGELIS:

No.

That's not -- I

don't believe that's how that works.

I think it has a

code that you can use to purchase it.

And then the

approval of it goes through -- essentially complying

with GFI 256.

And so I -THE COURT:

There is no actual order

for AMP in the record; correct -- that Dr. Scott

placed?

MR. DE ANGELIS:

Are you talking about

the purchase of AMP?

THE COURT:

MR. DE ANGELIS:

didn't put that in the record.

Yeah.

No.

We didn't -- we

THE COURT:

MR. DE ANGELIS:

briefly about the international scope of "any."

you look at the regulatory history, this definition

was modeled off of the World Anti-Doping Agency's

Code, the WADA Code.

modeled substantially off of its own definition of an

S0 prohibited substance, which says at page 3850 of

Okay.

So I just want to talk

It's almost taken -- it's

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the appeal book, which reads, "Any pharmacological

substance which is not addressed by any of the

subsequent sections of the list, and with no current

approval by any governmental regulatory health

authority for human therapeutic use, is prohibited at

all times." So --

THE COURT:

Well, how do you know

that's the model?

MR. DE ANGELIS:

Because that's what

the regulatory history says.

protocol, modeled it substantially off the World

Anti-Doping Agency's Code, the WADA.

THE COURT:

They adopted the

Well, I don't think it goes

quite that far to say that every rule was, you know,

had its model in WADA.

the ARCI S0 classification rule looks closer.

arises in the equine industry, rather than WADA, which

arises in, you know, largely the human athletic

industry.

model here, which I think is a bit overbroad.

MR. DE ANGELIS:

It seemed to me, frankly, that

And it

So I'm questioning, you know, your use of

I push back on that a

little bit because the protocol itself directs the use

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Page 33

of the WADA Code as a gap filler, and as an

interpretive aid, and not the ARCI.

THE COURT:

MR. DE ANGELIS:

two, I would agree that the ARCI has a similar

definition, but that is what's also taken from the FEI

and the WADA Code.

is the older organization, and that it draws from.

But regardless, the point that I'm

Yeah.

And so between the

And really, this -- WADA, I think,

trying to make here is that the rulemaking materials

reference WADA as sort of the inspiration for the

protocol.

European contract law that uses the law of Switzerland

as a gap filler.

And WADA is a body of contract law based on

So I just don't -- I think that this

argument that this was necessarily intended to have a

purely domestic reach is contrary to what they

requested in their rules, or what they -- how they

justified the rules to begin with.

THE COURT:

Well, I mean, I guess I see

some support for that proposition in this sense.

in proposing the ADMC rules, the Authority's study

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Yes,

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Page 34

group -- and I forget the exact name of it -- said we

looked to WADA.

the British Horseracing Authority.

RMTC.

We looked to the ARCI.

We looked to

We looked to the

All of those are international bodies.

So I guess I can accept that there was

an international perspective that informed what became

the ADMC rules.

That much I can agree with.

I'm not sure about how carefully

modeled things were on any of those particular, you

know, assortments of rules, some of which were

substantive, some of which were procedural, some of

which were laboratory standards.

wide-ranging non-U.S. limited focus.

MR. DE ANGELIS:

I mean, but it was a

Right.

I agree.

agree.

to put on this point is that -- the previous answer of

that page you put up referenced that if FDA approval

is not required, the lack of FDA approval can't

prohibit its use, can't disqualify it from use.

But the point -- the punctuation mark I want

There was a decision made that instead

of referencing that it's not approved by the FDA in

S0, they said "any" governmental regulatory authority.

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You have to presume that decision was deliberate

because the FDA has exclusive jurisdiction over drug

approvals.

If they intended "any" to mean just the

one agency, that's what they should have said.

they didn't.

effect to the word "any," it has to have a reach

beyond the United States.

left, but I -- in terms of the remedy, if you find the

merits --

They said "any."

THE COURT:

And so if -- to give

I only have 30 seconds

Well, I want to come to

that afterwards; okay?

MR. DE ANGELIS:

THE COURT:

Okay.

That, to me, is kind of a

separate consideration, not really part of the

argument on what do we do with AMP here; okay?

MR. DE ANGELIS:

But

Okay.

Oh, then the

last point -THE COURT:

I'll give you whatever time

you need to talk about that.

to limit yourself to a minute.

MR. DE ANGELIS:

So you don't even need

Okay.

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Okay.

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just -- the last point I want to make is that I

disagree that the GFI 256 is an affirmative defense

that we bear the burden on.

accurate reading is that it's an element negating

traverse on element 2.

if it doesn't comply with GFI 256, it's not approved

for use.

noncompliance.

I think that its more

That is their argument is that

And they would have the burden to show

And I do think that we made a

substantial showing of prejudice from the delay in

this case.

the label or even argue that there was an issue with

the label until six months afterwards.

actually reached out to them and asked if it would be

okay to purchase more AMP.

going to be their position that it would be a

prohibited substance.

That they didn't raise an issue regarding

And we had

And they said no.

It was

And so by that point, we couldn't

recover the label.

had been raised six months prior, it's possible that

this could have been recovered.

But and then they

changed their theory midstream.

But beyond that, it

And so there was a -- if the issue

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does -- the definition of a label under the FDA does

include accompanying material under section

21 U.S.C. 321(m).

And so the --

THE COURT:

the label argument; okay?

Yeah.

MR. DE ANGELIS:

case, that's all I have.

THE COURT:

I'm not wild about

Okay.

Well, in that

I mean, I think there are

other problems before you ever get to labels; so --

okay.

MR. DE ANGELIS:

Well, and then I'll

turn it back over to Ms. Farrell.

by, I think, a minute.

with her.

And I did go over

And I'm happy to share that

THE COURT:

Ms. Farrell, you have reply

MS. FARRELL:

I know you're not crazy

time.

about the label argument, but I would like to say very

briefly, I think it's important just to sort of

underscore here that Dr. Fenger speculated, you know,

distinctly, at the hearing, that there could have been

this label or additional insert.

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And now we find out today that, you

know, they tried to get it apparently, but they

couldn't or it doesn't exist.

to try to shift the blame to the Authority for not

asking them for label materials that should have been

in Scott's possession --

THE COURT:

We don't know.

But now

Ms. Farrell, the labels are

the least of your problem; okay?

MS. FARRELL:

THE COURT:

MS. FARRELL:

All right.

I got that one; all right?

Yep.

I've got it.

don't have anything else unless you have any specific

questions about our position.

THE COURT:

No.

I'm satisfied.

And I

think -- you know, I appreciate both sides having a

chance to tell me exactly where they're coming from.

And obviously, this is a serious question.

same time, the Authority can fix it.

like how I eventually come out, you've got the fix.

You have the pen.

MS. FARRELL:

THE COURT:

But at the

If they don't

Understood.

Yeah.

Okay.

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All right.

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Let's just go to the second part, which I asked the

parties to discuss the relief that might emerge here,

if I were to determine that the issues on sanctions

that the Authority has raised have some merit.

let's make sure that we're all on the same page

because I'm going to describe what I see as going on

here.

You have the arbitrator making an award

of 18 months ineligibility.

barred from servicing covered horses, or covered

horses period, at any covered racetrack for that time

period.

the arbitrator found, because he found two.

And it

starts to run from the date of the search.

That's the

backdating part of the award.

So Dr. Scott would be

The 18 months covers both the violations that

And then he also imposed a $25,000 fine

that, again, covers both of the violations that the

arbitrator found.

all of this is stayed pending this review.

the decision issues here, something's going to happen

to that stay unless it's extended; right?

And I appreciate, of course, that

But once

So the Authority's position, and this

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was the position I think that HIWU advanced in the

arbitration, and the Authority continues it here, is

that the two violations each carried 24 months of

suspension or ineligibility, and they should have been

made to run consecutively.

you'd have 48 months of exposure.

If that had been adopted,

Instead, there's only one 18-month

period.

arbitrator got from what the Authority would say is 48

months to 18.

Authority sees with the award.

And there's no explanation given for how the

So that's the first problem the

The second is the backdating because

there is a specific rule in the ADMC that says

backdating is okay if the charged party proves A, B,

C, and D, whatever it is.

determination that Dr. Scott proved the elements of

the backdating rule.

the Authority raises.

And there's no arbitrator

So that's the second point that

And the third point is, again, similar

to the ineligibility.

maximum, otherwise discretionary.

that if there were two violations, which the

The fine authority is a up to

And the position is

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July 22, 2026

Page 41

arbitrator found, that there should be accumulated

fines.

amount, which would be $50,000.

$25,000 fine.

The Authority would say each in the maximum

Instead, there's a

Again, not explained.

So have I got the Authority's position

right, Ms. Farrell?

MS. FARRELL:

THE COURT:

Yes.

Okay.

And I know Dr. Scott

argues that I don't have jurisdiction to deal with any

of this.

which said, I think I can deal with this even in spite

of the Serpe case, which came down amidst all of these

proceedings.

that.

And so we had the motion.

You got my order,

I explained why I thought I could do

I also said in that order that I was

not ruling on the merits of the Authority's position,

nor was I making any determination on what the relief

might be in the event I thought that there was

something about the sanctions that were indeed amiss,

and that they would have to be increased.

Although on reflection, it may simply

be that if I think there's something about the

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Page 42

sanctions that needs to be rethought, it's the same

problem.

Because as we know, there is a no-fault

argument.

There's a no significant fault argument.

think there's even a proportionality argument.

of them get met -- get addressed by the arbitrator.

None

And, you know, maybe if they were

addressed, the ineligibility period might come out to

be less than 18 months.

sort of what underlies my interest in talking about

this.

I don't know.

But that's

And that sort of changed again today

because the Commission issued two orders, one in

Overly and one in Juarez, where they said I should

reconsider the decisions in those two cases regarding

increased sanctions.

those two cases, along with dealing with what happens

in this particular case.

And so I will have to do that in

I suspect Mr. De Angelis doesn't know

about the Commission orders.

I don't know.

Ms. Farrell, you aren't in the office.

Maybe you don't know about them either.

MR. DE ANGELIS:

Actually --

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MS. FARRELL:

them.

THE COURT:

MS. FARRELL:

There's no escaping my

email.

Oh, you know about that?

Word travels fast.

I know about

My --

Oh, no.

MR. DE ANGELIS:

I also know about the

orders.

THE COURT:

Oh, my goodness.

You guys

really have bookmarks in someplace on the internet.

Okay.

here on AMP, so I thought that it might be useful to

talk a little bit about possible relief anyway.

Anyway, you know, I knew we were going to be

And, you know, I appreciate that I've

got to go through the whole array of questions.

Are

the violations -- are the two banned substances?

Are

the violations proven?

justification?

Dr. Scott has asserted.

What about compelling

And there are other defenses that

The whole business of sanctions and the

award doesn't come up until I get through all of that

and I think something's left.

And I said in my order

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that I thought this discussion needed to be without

prejudice to either side.

reason.

And I said that for a

You know, you're here today, and the

context isn't really well-defined.

decision, if I get -- have to get to the dealing with

the sanctions and the relief.

one or both of you may look at what I've done and say:

"Oh, my God, we can't live with this.

appeal to the Commission."

case pending at the same time.

think about the relief could very well be different

than what it is today when the context isn't defined

at all.

Once I do issue a

Now, you know, either

We're going to

Dr. Scott's got a federal

And what you might

So it does seem to me it's fair to both

of you to say that what you say here is without

prejudice.

hear what your views are; okay?

just, you know, want to go first, chafing at the bit,

so to speak.

Mr. De Angelis go first.

It's not an admission, but I'd like to

I bet you're both

I'll tell you what, I'll let

MR. DE ANGELIS:

Okay.

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Yeah.

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problem, Your Honor.

that in light of your order, maybe, like, how to make

it work, is that you might have the jurisdiction to

review the sanction, but you wouldn't have authority

to modify it upward.

review it for errors, but the relief would be limited.

I think that the relief that you could

The way that I read Serpe is

And so you could potentially

provide would be a remand for an explanation.

that that would probably be the cleanest order that

avoids a jurisdictional problem.

I think

Because there's, I think, a pretty

significant problem with the arbitrator's order is

that he never explains why he rejected our no

significant fault argument.

from the Court of Arbitration for Sport -- and one was

he sought, actually -- that we thought were pretty

directly on point on the fault analysis.

mention either case.

that those cases say you should consider.

THE COURT:

We gave him two cases

He doesn't

He doesn't mention the factors

No, I get that.

I get all

of that; okay?

MR. DE ANGELIS:

And so I think

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that -- but why I think that's an important first step

is, I think that this case is on very different

footing depending on what that explanation is.

know, does -- is this 18-month penalty, was that

intended to be two consecutive 9-month penalties?

don't know that.

was doing.

You

There's no explanation for what he

In terms of backdating, we don't know

why he did it.

took -- that this process is supposed to take only 74

days, and it took 247.

We do know that there was -- it

THE COURT:

You guys filed a bunch of

motions, in fairness.

MR. DE ANGELIS:

THE COURT:

MR. DE ANGELIS:

We did.

Okay.

But we -- that process

followed our initial objection on June 24th that we

wanted to stick by the schedule and the rules, that

was overruled.

best -- I think the cleanest remedy would be to

explain why he did what he did so that both parties

can review it for potential errors, and bring those to

And so I know -- I think that the

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Oral Argument

July 22, 2026

Page 47

your attention.

I don't think that -- because it's not

explained, it's difficult to say that there was no

record support because there's -- it's just not

reasoned.

entire order.

of the issues, and it would benefit the review process

if there was a remand for an explanation.

THE COURT:

Ms. Farrell?

MS. FARRELL:

And that was really our problem with the

But I think that clarifies the posture

Okay.

Yeah.

First, thank you

for the --

THE COURT:

everything he said.

quickly.

Maybe you agree with

I don't know.

MS. FARRELL:

THE COURT:

MS. FARRELL:

Then we'll end

Not -- not exactly.

Right.

Go ahead.

Thank you for this

without prejudice context because I am going to caveat

my response with, as of today, this is our position on

what we think should happen here.

So we do agree with Mr. De Angelis that

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Oral Argument

July 22, 2026

Page 48

you have the -- well, I think he said this.

the jurisdiction to review the issues at issue in the

case.

violations been committed?

analysis getting up to the sanction.

that's squarely within your purview to review the

merits of the case.

or not the sanction by the arbitrator was arbitrary

and capricious.

You have

Like you said, Your Honor, that -- have

You know, the whole

And we believe

And further, to determine whether

In looking at Serpe, it's the

Authority's position, you know, we have to follow the

guidance from Serpe that any modification to a

sanction must, by the Commission's definition, be

moderate or of a minor fashion.

And so what we don't know at this

point, because none of this is fleshed out in our case

law yet, you know, is it a moderate or minor change to

a single POI of 18 months?

species of sanction if you add a second period of

ineligibility that wasn't originally imposed?

moderate or minor change to add a second fine or

increase a fine?

You know, is it the same

There's so many unknowns with

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Is it a

FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 07/22/2026 OSCAR NO. 616139 -PAGE Page 49 of 70 * PUBLIC *

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Oral Argument

July 22, 2026

Page 49

exactly how -- what they would consider to be a

moderate or minor sanction.

And so the Authority's position is that

we would prefer that once you've reviewed the merits

of the case and made a determination as to the

arbitrary and capriciousness of the decision, that you

would remand to the arbitral body for sanctioning

consistent with your findings.

A more incremental approach is what the

Authority would like to see happen here.

an explanation from the arbitral body, but more, you

know, the actual determination of the sanctions should

be done by the arbitral body consistent with your

findings on the merits.

THE COURT:

Not exactly

Don't know -- well, okay.

Okay.

because it looks pretty clear that somewhere along the

way, whether it's in this case or one of the others,

the Commission's going to have to speak again.

are open questions here.

I'm reluctant to comment on this in part

There

Well, I do appreciate those views, and

you can be assured I will keep them in mind.

www.CapitalReportingCompany.com

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Anyone

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Oral Argument

July 22, 2026

Page 50

else want to say anything else?

MR. DE ANGELIS:

MS. FARRELL:

No, Your Honor.

THE COURT:

adjourn.

Okay.

MS. FARRELL:

MR. DE ANGELIS:

THE COURT:

I think then we can

I have nothing more.

Thank

you.

No, Your Honor.

Thank you.

Thank you, Your Honor.

Thanks very much.

Appreciate the time.

THE REPORTER:

All right.

The time is

11:57 a.m., and we're off the record.

(Whereupon, at 11:57 a.m., the

proceeding was concluded.)

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Oral Argument

July 22, 2026

Page 51

CERTIFICATE

I, HELEN TADESSE, the officer before whom

the foregoing proceedings were taken, do hereby

certify that any witness(es) in the foregoing

proceedings, prior to testifying, were duly sworn;

that the proceedings were recorded by me and

thereafter reduced to typewriting by a qualified

transcriptionist; that said digital audio recording of

said proceedings are a true and accurate record to the

best of my knowledge, skills, and ability; that I am

neither counsel for, related to, nor employed by any

of the parties to the action in which this was taken;

and, further, that I am not a relative or employee of

any counsel or attorney employed by the parties

hereto, nor financially or otherwise interested in the

outcome of this action.

HELEN TADESSE

Notary Public in and for the

Commonwealth of Virginia

Job No. CS8343288

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Oral Argument

July 22, 2026

Page 52

CERTIFICATE OF TRANSCRIBER

I, SANDRA BECK, do hereby certify that this

transcript was prepared from the digital audio

recording of the foregoing proceeding, that said

transcript is a true and accurate record of the

proceedings to the best of my knowledge, skills, and

ability; that I am neither counsel for, related to,

nor employed by any of the parties to the action in

which this was taken; and, further, that I am not a

relative or employee of any counsel or attorney

employed by the parties hereto, nor financially or

otherwise interested in the outcome of this action.

SANDRA BECK

Dated: August 3, 2026

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Oral Argument

[& - adopted]

& 2:4,10,12

4:14

1 11:14,17 30:2

11:01 1:11 6:2

11:57 50:12,13

18 39:9,12 40:7

40:10 42:8

46:4 48:18

1970s 12:1

2 15:5 18:6

19:5,13 36:5

20 6:11

201 3:6

2024 13:16

19:1

2025 6:11 9:8

2026 1:10

52:21

20580 1:15

21 37:3

214 30:10

21st 2:5

22 1:10

24 40:3

247 46:11

24th 46:17

25,000 39:16

41:4

July 22, 2026

Page 1

256 14:9,15

17:3,4,7,10

23:2 29:1,1,12

31:6 36:2,6

2617 2:5

285-1425 2:16

29875 52:16

3 19:11,14,20

20:8 52:21

30 35:8

321 37:3

340 3:6

34163 51:19

350 2:13

3850 31:22

40507 3:7

4111 6:14 10:1

10:12 17:16

4112 11:15

4117 11:15

48 40:6,9

4801 2:13

50 12:5

50,000 41:3

5018 15:18

513-2919 3:9

520 30:2

5391 13:12

552 30:10

600 1:14

64112 2:14

651 10:9

74 46:10

74114 2:6

742-2021 2:8

816 2:16

8343288 1:17

877 3:9

9 46:5

918 2:8

9449 1:7 6:8

a.m. 1:11 6:2

50:12,13

abbreviation

6:11

ability 51:12

52:9

absurd 12:21

accept 18:19

34:5

acceptance

19:21

accompanying

37:2

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accumulated

41:1

accurate 36:4

51:11 52:7

acepromazine

20:19

acting 30:13

action 27:18

51:14,18 52:10

52:14

actual 31:7

49:12

actually 22:2,5

36:14 42:22

45:16

ad 6:13

add 48:19,21

additional

14:11 37:22

addressed 32:2

42:5,7

adjourn 50:6

admc 9:21,22

33:22 34:7

40:13

administration

4:8,10

administrative

1:3,12 8:14

admission

44:17

adopted 32:10

40:5

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Oral Argument

[advance - arbitrator]

advance 10:22

advanced 40:1

advisor 4:6

afarrell 2:15

affirmative

36:2

agency 35:5

agency's 31:19

32:12

ages 22:21

ago 22:21

agree 11:14

17:14,20 19:14

33:5 34:7,14

34:15 47:13,22

agreed 23:4

agreement 25:8

ahead 11:6

12:11 14:19

15:2 47:17

aid 33:2

alert 19:8

ali 30:9,9

alj 6:5 18:13

allison 2:11 7:4

10:16

allowed 11:8

alonzo 4:12

alternatives

20:17

amdc 6:13

amduca 10:8

20:16

July 22, 2026

Page 2

america 1:1

amidst 41:12

amiss 41:19

amount 41:3

amp 6:10 9:11

9:19,20 10:12

11:11,14 12:2

12:4,15,20

13:8,11 14:5,5

14:6,8 18:21

20:11 21:15,15

22:11 23:20

24:1,5 26:4

28:9,10,11,16

28:19 31:1,8

31:11 35:16

36:15 43:12

analysis 45:17

48:5

angelis 2:3,4

4:15 6:20,21

21:12,13,19

22:7,22 23:13

23:19 24:7,10

24:15 25:1,14

25:22 26:2,8

26:11,16 27:1

27:7,10,13

28:2,20,22

29:16 31:2,10

31:13,16 32:9

32:21 33:4

34:14 35:13,17

35:22 37:6,11

42:18,22 43:7

44:21,22 45:22

46:14,16 47:22

50:2,8

answer 16:14

27:8 29:11

34:16

anti 31:19

32:12

anybody 7:17

anyway 43:11

43:13

apologize 10:22

14:19

apparently

38:2

appeal 13:12

15:19 21:21

32:1 44:10

appearances

6:15

appearing 7:8

appellant 1:7

2:2 4:16 6:18

12:14 14:10

applicability

17:21

application

13:7 23:3,9

24:16,18 25:16

applications

23:20 24:1,21

applied 21:22

25:17

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applies 12:22

17:11

appreciate

38:15 39:18

43:14 49:21

50:10

approach

28:17 49:9

approaching

28:14

approval 11:19

12:2,6,17 15:7

19:6 22:16,20

23:1,6 29:17

31:1,5 32:4

34:17,18

approvals

22:18 35:3

approved

12:15,20 13:9

20:17,21 23:10

34:21 36:6

arbitral 49:7

49:11,13

arbitrary 48:8

49:6

arbitration

9:16 40:2

45:15

arbitrator 9:16

39:8,13,18

40:9,15 41:1

42:5 48:8

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Oral Argument

[arbitrator's - book]

arbitrator's

45:12

arci 32:16 33:2

33:5 34:2

argue 6:10

36:12

argued 12:8,13

12:14,14

argues 9:22

41:9

argument 1:9

6:8 7:12,20 8:5

8:20 9:18

14:22 28:13

30:3,11,21

33:16 35:16

36:5 37:5,18

42:3,3,4 45:14

arises 32:17,18

array 43:15

asberry 4:10

asked 6:8,9

36:14 39:1

asking 19:12

24:13 38:5

asserted 43:19

assertion 15:10

assigned 6:6

assortments

34:10

assume 15:6

17:19

assured 49:22

July 22, 2026

Page 3

athletic 32:18

attend 7:14

attending 6:17

8:14

attention 8:1

47:1

attentive 7:18

attorney 4:3,6

51:16 52:12

audio 9:2 51:10

52:5

august 52:21

australia 22:19

29:17

australian

12:15,20 13:1

13:11 18:14

31:1

authority 3:3,5

7:2,4,8 9:12

10:14,16 11:20

12:7,18 15:6

15:10 19:3

22:17 32:5

34:3,22 38:4

38:18 39:4

40:2,9,11,18,20

41:2 45:4

49:10

authority's

12:19 14:9

16:22 18:9,12

18:16 33:22

39:22 41:5,16

48:11 49:3

authorized

8:19

available 13:11

avenue 1:14

avoid 22:2

avoids 45:10

award 39:8,15

40:11 43:21

aware 11:10

16:15 18:22

19:7,9

b 5:1 40:14

back 27:2

32:21 37:12

backdating

39:15 40:12,14

40:17 46:8

background

10:22

backwards

25:11

bank 29:7

banned 6:13

9:10,13,21

10:4 11:11

17:15 22:11

28:9,11,12,16

43:16

barking 10:21

barred 39:10

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based 16:8

18:14 33:12

basic 17:16

18:5

basically 14:21

beach 4:10

bear 36:3

beck 52:4,17

began 9:17

behalf 2:2,10

3:2 7:4 10:16

believe 24:12

25:1 31:3 48:5

benefit 14:11

25:11 47:7

benson 20:9,15

benson's 12:1

20:18

best 13:4 46:20

51:12 52:8

bet 44:18

beyond 35:8

36:22

bigger 15:22

bit 15:2 16:1

20:8 32:20,22

43:13 44:19

blame 38:4

board 16:10

bodies 34:4

body 33:12

49:7,11,13

book 13:12

15:19 32:1

FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 07/22/2026 OSCAR NO. 616139 -PAGE Page 56 of 70 * PUBLIC *

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Oral Argument

[bookmarks - concerns]

bookmarks

43:10

bow 19:19

box 11:16

boy 15:21

brewster 2:4

4:14

brewsterlaw....

2:7

brief 28:13

briefing 6:9

briefly 8:18

31:17 37:19

bring 15:18

46:22

british 34:3

broadly 22:2

bulk 13:7,8,16

23:3 29:2

bunch 46:12

burden 17:15

17:20 18:5

36:3,7

bureau 30:10

business 43:20

buy 23:17

c 2:1 3:1 4:1 6:1

40:15

call 7:6

called 10:4,8,9

capacity 30:13

capricious 48:9

capriciousness

49:6

captures 10:2

carefully 34:8

carried 40:3

carve 10:6,7

14:12 17:6,10

17:19,21

case 6:6,9 8:12

13:4 14:14,15

19:3 28:6

36:11 37:7

41:12 42:17

44:11 45:18

46:2 48:3,7,16

49:5,18

cases 18:21

29:22 30:14

42:14,16 45:14

45:19

catastrophic

10:19

catchall 9:22

categorically

22:12,12 28:16

caveat 47:19

certain 10:3

29:4

certainly 18:15

19:19

certificate 51:3

52:3

July 22, 2026

Page 4

certified 16:10

certify 51:6

52:4

chafing 44:19

chance 38:16

change 48:17

48:21

changed 36:22

42:11

changes 20:19

20:20

charged 9:14

40:14

charges 9:16

checks 11:16

chief 28:14

circumvent

21:22

city 2:14

clarifies 47:6

classification

10:4 16:3

32:16

classified 6:12

cleanest 45:9

46:20

clear 9:4 25:16

49:17

closer 32:16

code 31:4,20,20

32:12 33:1,7

colleges 16:9

come 7:17

35:11 38:19

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42:7 43:21

coming 38:16

comment 15:11

16:2 49:16

commission 1:2

4:4,7,9,11,13

6:6 42:12,19

44:10

commission's

48:13 49:19

committed 48:4

commonwealth

51:22

communicati...

27:3

compelling

43:17

compile 26:4

compliance

29:8

comply 29:4

36:6

complying 31:5

comport 14:10

compound 23:7

24:12 29:2

compounded

13:22 14:7

21:1 26:3

compounding

13:9 23:2

concerns 9:19

19:20

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Oral Argument

[concluded - defense]

concluded 30:6

50:14

conducted 7:12

confidential

7:14,22

confidentiality

7:20

confirm 24:16

conflict 17:3

consecutive

46:5

consecutively

40:5

consider 10:11

45:19 49:1

consideration

15:12 35:15

considered

14:6

consistent 49:8

49:13

consistently

29:19

consult 19:17

cont'd 3:1 4:1

contact 26:17

contend 9:13

context 44:5,13

47:19

continues 40:2

contract 33:12

33:13

contrary 33:17

July 22, 2026

Page 5

copy 26:12

correct 7:10

12:10 13:19

14:2 15:7 18:3

22:11 31:8

counsel 4:4 7:5

7:21 8:22 9:3

10:13 51:13,16

52:9,12

count 22:21

course 39:18

court 6:4 7:1,7

7:11 8:6,7,9,10

9:4 11:2,6 12:9

12:11 13:2,4

13:14,20 14:4

14:13,17 15:3

15:9,15,18,21

16:6,13,20

17:6,14,18

18:2,4,19 19:2

19:10,19 20:3

21:3,6,11,17

22:5,20 23:11

23:14 24:4,8

24:13,20 25:5

25:20 26:1,6,9

26:14,21 27:5

27:9,11,22

28:18,21 29:15

29:20 30:22

31:7,12,15

32:7,13 33:3

33:20 35:11,14

35:19 37:4,8

37:15 38:7,10

38:14,22 41:8

43:3,9 45:15

45:20 46:12,15

47:9,13,17

49:15 50:5,9

coverage 10:7

covered 9:22

10:12 39:10,10

39:11

covers 39:12,17

crazy 37:17

criteria 10:3,5

11:17 22:13

cs8343288

51:22

current 11:19

12:6 22:16

32:3

customs 30:13

cut 20:5

d 6:1 40:15

dana 4:8

dantrolene

20:19

date 1:10 25:18

39:14

dated 52:21

days 18:20

46:11

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dc 1:15

de 2:3,4 4:15

6:20,20 21:12

21:13,19 22:7

22:22 23:13,19

24:7,10,15

25:1,14,22

26:2,8,11,16

27:1,7,10,13

28:2,20,22

29:16 31:2,10

31:13,16 32:9

32:21 33:4

34:14 35:13,17

35:22 37:6,11

42:18,22 43:7

44:21,22 45:22

46:14,16 47:22

50:2,8

deal 41:9,11

dealing 42:16

44:6

dealt 11:15

decides 18:13

decision 34:20

35:1 39:20

44:6 49:6

decisions 22:3

42:14

deemed 11:11

12:2

defend 28:16

defense 36:2

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Oral Argument

[defenses - exercise]

defenses 43:18

defined 44:5,13

defines 30:16

definition

31:18,21 33:6

37:1 48:13

delay 36:10

deliberate 35:1

delineated 10:3

departed 22:8

depending 46:3

describe 39:6

description 5:2

designation

16:7 17:1

determination

40:16 41:17

49:5,12

determine 39:3

48:7

determining

18:10

diet 20:19

different 44:12

46:2

difficult 47:3

digital 51:10

52:5

directly 45:17

directs 32:22

disagree 36:2

discretion 17:5

29:4

July 22, 2026

Page 6

discretionary

40:21

discuss 39:2

discussion 44:1

dispute 11:22

disqualify

34:19

distinctly 37:21

distribute

28:19

distributor

26:3,12

diversion 14:18

docket 1:6 6:7

8:12 23:20

24:3 25:3

dog 10:21

doing 22:8 46:7

domestic 33:17

doping 31:19

32:12

dr 6:12,19,21

9:8,14,17 12:1

13:13,17,18

17:20 20:9,15

20:18 23:16

25:11 26:17

30:22 31:8

37:20 39:9

40:16 41:8

43:19 44:10

draws 33:8

drug 12:15

13:7,9,16 21:1

35:2

drugs 20:21

duly 51:7

dvm 1:6 2:2

4:16

e 2:1,1 3:1,1 4:1

4:1 5:1 6:1,1

earlier 25:10

easier 29:18

east 2:5 3:6

effect 10:6 35:7

effective 12:3

either 6:17 7:21

17:21 42:21

44:2,7 45:18

element 36:4,5

elements 40:16

email 43:6

emerge 39:2

employed

51:13,16 52:10

52:13

employee 51:15

52:12

enforced 29:13

enforcement

17:4 19:4 29:3

30:12,12

ensuing 9:15

entire 21:21

47:6

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equine 24:6,8

25:21,22 26:22

27:12 32:17

errors 45:6

46:22

es 51:6

escaping 43:5

esquire 2:3,11

3:4

essentially

10:10 31:5

european 33:13

evd 5:2

event 41:18

eventually

38:19

everybody 6:4

evidence 20:9

20:18 23:17

evolving 16:8

17:2

exact 34:1

exactly 15:14

16:18 38:16

47:16 49:1,10

exception 18:2

18:5

exceptions 15:1

20:16

excise 30:13

exclusive 29:9

35:2

exercise 20:20

29:3

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Oral Argument

[exhibits - gfi]

exhibits 24:19

exist 17:4 19:9

24:17 38:3

existing 20:10

expert 19:17

20:9

experts 23:4

explain 19:12

46:21

explained 41:4

41:13 47:3

explains 45:13

explanation

40:8 45:8 46:3

46:6 47:8

49:11

explanations

22:9

explicitly 13:10

exposure 40:6

expressly 9:20

12:4

extended 25:10

39:21

extent 23:6

fact 12:20

factors 45:18

fair 14:14

19:10 44:15

fairness 46:13

familiar 9:8

July 22, 2026

Page 7

far 32:14

farrell 2:11 7:3

7:4,10 10:15

10:16 11:4,7

12:10,12 13:3

13:6,19 14:2,5

14:16,20 15:8

15:13 16:4,5

16:12,17,21

17:12,17 18:1

18:3,8,22 19:7

19:16 20:1,7

21:4,8 37:12

37:15,17 38:7

38:9,11,21

41:6,7 42:20

43:1,5 47:10

47:11,16,18

50:3,7

fashion 48:14

fast 43:4

fault 42:2,3

45:14,17

fda 10:10 12:1

12:5 13:8,10

20:16,21 22:19

22:20 23:6,15

25:3 27:17

29:9,9 34:17

34:18,21 35:2

37:1

fda's 23:6

26:18

february 6:11

9:8

federal 1:2 4:4

4:6,8,11,12 6:6

10:8 12:22

18:11,18 28:19

29:2 30:4,5,10

44:10

feed 7:13

feel 27:17

fei 33:6

fenger 37:20

filed 8:12 46:12

filler 33:1,14

finalized 8:11

finally 8:13

financially

51:17 52:13

find 24:16 28:1

35:9 38:1

findings 49:8

49:14

fine 21:8 39:16

40:20 41:4

48:21,22

fines 41:2

first 10:14

11:13 17:9

30:1 40:10

44:19,21 46:1

47:11

five 11:8 21:9

fix 38:18,19

www.CapitalReportingCompany.com

202-857-3376

fleshed 48:16

flooding 10:19

focus 34:13

follow 14:8

48:11

followed 46:17

footing 46:3

foregoing 51:5

51:6 52:6

forget 34:1

found 6:11

7:16 9:10

26:14,16 28:11

39:13,13,18

41:1

four 6:7

frankly 32:15

ftc 8:15

ftc's 8:4,13

further 14:8

48:7 51:15

52:11

g 6:1

gap 33:1,14

general 4:4 7:5

getting 18:6

48:5

gfi 10:9 14:9,15

17:3,4,7,10

23:2 28:22

29:1,12 31:6

36:2,6

FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 07/22/2026 OSCAR NO. 616139 -PAGE Page 60 of 70 * PUBLIC *

PUBLIC

Oral Argument

[give - integrity]

give 10:18

11:22 25:2

26:13 35:6,19

given 40:8

go 11:6 12:11

14:19 27:2

28:4 29:5

37:12 39:1

43:15 44:19,21

47:17

god 44:9

goes 31:5 32:13

going 12:13

13:14 14:22

18:17 20:22

21:14,14 29:5

29:8 36:16

39:6,6,20

43:11 44:9

47:19 49:19

gonzales 30:2

good 6:4 7:3,7

8:8 10:13

21:17,17,17

goodness 43:9

governmental

11:20 12:7,17

22:16 32:4

34:22

grabbed 24:17

gross 4:8

group 34:1

guess 16:15

33:20 34:5

July 22, 2026

Page 8

guidance 23:2

23:7 48:12

guys 43:9 46:12

h 5:1

hands 7:22

happen 39:20

47:21 49:10

happens 42:16

happy 37:13

hard 19:14

heads 10:18

health 11:20

22:16 32:4

hear 10:13

44:18

hearing 8:5

37:21

heart 14:21

heather 4:14

6:22

helen 1:16 8:9

51:4,20

hereto 51:17

52:13

highlight 20:8

himes 1:12 6:5

hisa 7:5 28:7

hisa's 30:20

hisaus.org 3:8

history 31:18

32:10

hiwu 7:9 9:8,10

9:11,14,21

11:2 19:3 28:7

40:1

hiwu.org 2:15

holding 30:8

honor 6:20 7:4

7:10 10:15

11:9 16:12

19:18 21:10,13

45:1 48:3 50:2

50:3,8

horseracing

2:10,12 3:2,5

9:12 34:3

horses 39:10,11

human 11:21

22:17 32:5,18

hundred 24:1

24:21

identified 7:13

9:20 10:2

identify 6:16

8:7 9:3

ii 17:8

imagination

7:15

implement 8:2

implicitly 15:5

important 20:6

27:14 37:19

46:1

www.CapitalReportingCompany.com

202-857-3376

importantly

20:15

imposed 39:16

48:20

imprisonment

30:4,5,7

include 37:2

includes 30:12

increase 48:22

increased

41:20 42:15

incremental

49:9

indiscriminat...

29:20

individual

16:10

individuals

8:19

industry 32:17

32:19

ineligibility

39:9 40:4,20

42:7 48:20

informal 10:18

informed 34:6

initial 46:17

insert 37:22

inspiration

33:11

instructions

8:17

integrity 2:10

2:12 3:2,5 9:12

FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 07/22/2026 OSCAR NO. 616139 -PAGE Page 61 of 70 * PUBLIC *

PUBLIC

Oral Argument

[intended - location]

intended 33:16

35:4 46:5

interest 42:9

interested

51:17 52:14

intern 4:12

international

16:9 17:2

18:15 31:17

34:4,6

internet 43:10

interpret 18:10

18:11,17

interpretation

12:21

interpreted

29:19

interpreting

22:1,6

interpretive

19:5 33:2

interrupted

14:18

investigating

28:15

investigators

9:10

irrelevant

12:21

issue 7:19

27:16,20 28:6

36:11,12,19

44:5 48:2

July 22, 2026

Page 9

issued 19:4

42:12

issues 28:5 39:3

39:20 47:7

48:2

jason 1:6 2:2

4:16

jay 1:12

jcdeangelis 2:7

job 1:17 51:22

joseph 2:3 6:20

juarez 42:13

judge 1:12 6:5

judges 1:3 8:14

july 1:10

june 46:17

jurisdiction

29:9 35:2 41:9

45:3 48:2

jurisdictional

45:10

justification

43:18

justified 33:19

justify 22:2

kansas 2:14

keep 49:22

kind 16:15

23:15 29:21

35:14

knew 43:11

know 6:5 7:22

10:21 15:13

16:21 17:8

19:10,22 20:9

20:15,18 25:20

26:9 27:19

32:7,14,18,19

34:10 37:17,20

38:2,3,15 41:8

42:2,6,8,18,19

42:21 43:1,3,7

43:11,14 44:4

44:7,19 46:4,6

46:8,9,19

47:14 48:4,11

48:15,17,18

49:12,15

knowledge

51:12 52:8

koepke 4:6

15:17,20

ky 3:7

l 1:12

label 24:6

26:13 36:12,13

36:19 37:1,5

37:18,22 38:5

labels 37:9 38:7

laboratory

34:12

www.CapitalReportingCompany.com

202-857-3376

lack 34:18

language 19:21

22:15 30:18

largely 32:18

lashaon 4:10

law 1:3,12 8:14

12:22 13:1

18:9,17 28:19

29:2 30:12,12

33:12,13,13

48:17

leave 25:12

left 35:9 43:22

legal 4:8,10,12

lesson 30:14

lexington 3:7

light 45:2

limit 35:21

limited 19:22

23:10 34:13

45:6

link 7:16 8:20

list 11:16 13:8

13:16 32:3

listed 11:16

13:8

literature

20:10

litigation 4:3

little 15:2 16:1

32:22 43:13

live 44:9

location 1:13

FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 07/22/2026 OSCAR NO. 616139 -PAGE Page 62 of 70 * PUBLIC *

PUBLIC

Oral Argument

[logistics - note]

logistics 8:5,16

long 14:7

look 12:1 16:6

18:9 25:3 27:2

27:14 31:18

44:8

looked 34:2,2,2

34:3

looking 18:17

48:10

looks 32:16

49:17

lot 24:3

m 37:3

made 24:19

34:20 36:9

40:5 49:5

main 2:13 3:6

make 15:21

28:12 33:10

36:1 39:5 45:2

making 39:8

41:17

managing 8:4

mark 34:15

marked 5:3

material 37:2

materials 33:10

38:5

matter 1:5 6:7

19:13 28:15

July 22, 2026

Page 10

maximum

40:21 41:2

mean 14:20

17:12 18:13

20:7 27:14

29:20 33:20

34:12 35:4

37:8

means 11:18

23:9

meant 30:4

medication

27:17 28:8

medications

26:3

medicine 16:10

23:5

meet 10:2

22:13

member 7:15

8:15

members 7:13

8:13

mention 45:18

45:18

mentioned 10:1

merit 39:4

merits 6:9

35:10 41:16

48:7 49:4,14

met 10:5 11:10

42:5

mexico 9:9

michael 4:12

middle 16:3

midstream

36:22

mind 15:22

49:22

minor 48:14,17

48:21 49:2

minute 35:21

37:13

minutes 11:8

20:4 21:9

mo 2:14

model 32:8,15

32:20

modeled 31:19

31:21 32:11

34:9

moderate 48:14

48:17,21 49:2

modification

48:12

modify 45:5

month 40:7

46:4,5

months 28:13

36:13,20 39:9

39:12 40:3,6

40:10 42:8

48:18

morning 6:4

7:3 8:8

motion 41:10

www.CapitalReportingCompany.com

202-857-3376

motions 46:13

n 2:1 3:1 4:1

6:1

name 27:2 34:1

narrowly 22:6

necessarily

33:16

necessary 8:2

14:11 25:15

need 35:20,20

needed 28:15

44:1

needs 42:1

negate 10:6

negating 36:4

neither 12:2

19:3 51:13

52:9

never 15:22

45:13

new 9:9

nomination

13:15,21 23:16

24:9,11 26:19

nominations

25:9

non 10:2 34:13

noncompliance

36:8

notary 51:21

note 7:5 21:14

FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 07/22/2026 OSCAR NO. 616139 -PAGE Page 63 of 70 * PUBLIC *

PUBLIC

Oral Argument

[noted - please]

noted 22:17

notice 28:10

number 6:7

10:9 11:14,17

11:18 20:8

23:20 24:3

25:3 26:14,16

numerous 25:4

nw 1:14

o 6:1

oalj 8:4

oath 19:8

objection 46:17

obtain 26:12

obviously 7:11

38:17

office 1:3 4:3

8:4,14 10:20

42:20

officer 30:12

51:4

officers 30:13

official 11:3,5

oh 12:12 15:21

15:22 16:20

35:17 43:1,3,9

44:9

ok 2:6

okay 7:1,7,11

11:6 14:4,17

15:15 16:13,20

19:10 20:3

July 22, 2026

Page 11

21:3,8,11

23:14 24:14

25:9 29:15

31:15 35:12,13

35:13,16,17,22

35:22 36:15

37:5,6,10 38:8

38:22 40:14

41:8 43:11

44:18,22 45:21

46:15 47:9

49:15,16 50:5

older 33:8

omission 25:6

once 8:11 39:19

44:5 49:4

ones 25:10

ons 24:3

open 49:20

opposite 12:6

oral 1:9 6:8

order 11:9,11

24:11 31:7

41:10,15 43:22

45:2,9,12 47:6

orders 42:12,19

43:8

organization

27:20 33:8

originally

48:20

outcome 51:18

52:14

outs 10:6,7

17:19,21

overbroad

32:20

overly 42:13

overruled

46:19

overturned

9:18

own 18:18

31:21

p 2:1,1 3:1,1

4:1,1 6:1

page 15:18

16:3 31:22

34:17 39:5

paralegal 4:14

6:21

park 9:9

part 6:9 19:20

35:15 39:1,15

49:16

particular 34:9

42:17

parties 6:10,16

11:22 39:2

46:21 51:14,16

52:10,13

party 40:14

pen 38:20

penalties 46:5

www.CapitalReportingCompany.com

202-857-3376

penalty 46:4

pending 13:21

18:21 19:1

23:8,9 25:9

39:19 44:11

pennsylvania

1:14

people 20:5

period 15:11

23:15 25:17

39:11,12 40:8

42:7 48:19

permission

23:5

permits 23:2

person 7:9

perspective

34:6

pertinent 28:5

petition 23:8

pharmaco 24:6

24:8 25:21,21

25:22 26:22

27:12

pharmacolog...

32:1

pharmacy 13:7

phone 26:14,16

picked 25:18

25:18

placed 31:9

please 6:16 8:7

9:2

FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 07/22/2026 OSCAR NO. 616139 -PAGE Page 64 of 70 * PUBLIC *

PUBLIC

Oral Argument

[plenty - raise]

plenty 20:20

pllc 2:4 4:15

poi 48:18

point 12:13

13:1,6 19:18

19:18 26:18

27:6 33:9

34:15,16 35:18

36:1,18 40:17

40:19 45:17

48:16

policy 10:10

19:4 22:2

position 12:19

14:10 18:9,12

18:16 36:16

38:13 39:22

40:1,21 41:5

41:16 47:20

48:11 49:3

possession 9:15

9:19 38:6

possible 28:18

36:20 43:13

possibly 25:12

posture 47:6

potential 46:22

potentially

45:5

practice 31:1

prefer 49:4

prejudice

36:10 44:2,17

47:19

July 22, 2026

Page 12

preliminary

21:14

prepared 52:5

prescott 4:14

6:22

present 4:2 7:6

presume 35:1

pretty 8:2

10:19 25:5

45:11,16 49:17

prevent 20:11

previous 34:16

previously 10:1

principal 24:2

prior 19:2

36:20 51:7

prisons 30:10

probably 29:18

45:9

problem 18:6

21:20 38:8

40:10 42:2

45:1,10,12

47:5

problems 37:9

procedural

34:11

procedures

8:18

proceed 10:13

proceeding

1:13 7:14 9:17

50:14 52:6

proceedings

9:7 41:13 51:5

51:7,8,11 52:8

process 22:1,3

22:10 46:10,16

47:7

prohibit 34:19

prohibited

11:16 22:13

31:22 32:5

36:17

proof 14:15

proper 22:3

properly 6:12

proportionality

42:4

proposing

33:22

proposition

13:5 33:21

protocol 32:11

32:22 33:12

proved 40:16

proven 14:14

43:17

proves 40:14

provide 45:8

provided 22:9

provides 23:7

public 7:14,16

27:12 51:21

publicly 7:13

punctuation

34:15

www.CapitalReportingCompany.com

202-857-3376

purchase 31:4

31:11 36:15

purely 33:17

purpose 23:10

purview 18:16

48:6

push 32:21

put 23:21,22

24:8 31:14

34:16,17

putting 24:11

qualified 51:9

question 13:2

15:4 19:15

23:11 27:8

29:10,12,18

38:17

questioning

32:19

questions 10:12

38:13 43:15

49:20

quick 10:17

quickly 11:12

21:5 47:15

quite 32:14

r 2:1 3:1 4:1 6:1

racetrack 9:9

39:11

raise 36:11

FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 07/22/2026 OSCAR NO. 616139 -PAGE Page 65 of 70 * PUBLIC *

PUBLIC

Oral Argument

[raised - resolved]

raised 7:20

27:16,21 28:7

36:20 39:4

raises 40:18

range 25:18

ranging 34:13

rather 20:22

30:17 32:17

reach 33:17

35:7

reached 26:11

30:6 36:14

read 16:11

30:18 45:1

reading 30:9

36:4

reads 32:1

reaffirmed

30:8,9

really 10:17

21:5 27:14

33:7 35:15

43:10 44:5

47:5

reason 44:3

reasoned 47:5

recent 24:18

recognition

18:14

recognize 21:7

recognized

16:8 17:2

20:13,14

July 22, 2026

Page 13

reconsider

42:14

record 6:3

22:18 23:21

24:5,21 25:13

26:7 27:6 31:8

31:14 47:4

50:12 51:11

52:7

recorded 51:8

recording

51:10 52:6

recover 36:19

recovered

36:21

reduced 51:9

refer 21:15

30:16

reference 33:11

referenced

34:17

referencing

29:21 34:21

referring 15:14

16:14,18,19

23:1

refers 15:6

reflection

41:21

regarding

36:11 42:14

regardless 33:9

regime 18:15

regs 18:18

regulation

12:22 15:4

18:11 30:17

regulations

22:4

regulators

12:16,20 16:9

17:3

regulatory

11:20 12:7,17

18:15 22:16

31:18 32:4,10

34:22

reinhardt 3:4

7:6

rejected 12:4

13:10,16 26:19

30:3,11 45:13

rejects 23:15

relate 10:7

related 51:13

52:9

relates 19:6

relative 51:15

52:12

relief 39:2

41:17 43:13

44:7,12 45:6,7

reluctant 49:16

rely 30:22

remand 45:8

47:8 49:7

www.CapitalReportingCompany.com

202-857-3376

remedy 35:9

46:20

remember 27:1

remote 1:13

remotely 7:6

reply 37:15

report 12:1

21:2

reported 1:16

reporter 6:2

8:6,7,8,9 9:4

50:11

represent

26:10

requested

33:18

required 23:6

24:11 34:18

requirement

11:14,18,21

12:16 15:5

17:8 20:2,8

requirements

11:10,13 14:9

14:11 17:4,16

29:5

requires 30:18

research 20:10

21:1

reserve 11:8

21:6,9

resist 19:11

resolved 19:1

FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 07/22/2026 OSCAR NO. 616139 -PAGE Page 66 of 70 * PUBLIC *

PUBLIC

Oral Argument

[respect - serpe]

respect 18:12

respond 21:9

respondent

12:14

response 11:8

16:7,22,22

47:20

rethought 42:1

review 9:7,13

9:17 13:22

14:7 23:3,15

39:19 45:4,6

46:22 47:7

48:2,6

reviewed 49:4

revise 18:13

revised 16:8

17:1

revising 18:20

revision 22:1

rhabdomyoly...

20:14,22

right 7:9 11:6

14:19 16:3,3

16:16 17:22

19:2 20:3

22:10,22 24:6

34:14 38:9,10

38:22 39:21

41:6 47:17

50:11

rise 11:22

risk 18:19

July 22, 2026

Page 14

rmtc 34:4

road 28:4

robert 4:3

room 6:17

rule 6:14 10:1,2

10:3,5,12 15:4

18:5,12 20:2

22:6 32:14,16

40:13,17

rulemaking

21:22 22:9

33:10

rules 6:14 9:21

11:15 15:11

21:21 22:1

27:15 33:18,19

33:22 34:7,10

46:18

ruling 41:16

run 11:12

39:14 40:5

s 2:1 3:1 4:1 5:1

6:1

s0 6:13 10:4

16:2 22:13

31:22 32:16

34:22

safe 12:3

safety 3:2,5

9:12

samuel 3:4 7:5

samuel.reinh...

3:8

sanction 45:4

48:5,8,13,19

49:2

sanctioning

49:7

sanctions 39:3

41:19 42:1,15

43:20 44:7

49:12

sandra 52:4,17

sarapin 9:11

satisfied 14:15

38:14

satisfies 12:16

satisfy 19:13,14

says 11:19

22:15 29:1,12

31:22 32:10

40:13

scanning 21:4

schedule 46:18

scope 31:17

scott 1:6 2:2

4:16 6:7,19,21

9:14,17 17:20

23:16 25:11

26:17 30:22

31:8 39:9

40:16 41:8

43:19

scott's 6:12 9:8

13:17,18 38:6

www.CapitalReportingCompany.com

202-857-3376

44:10

screen 15:16

scroll 16:1

se 19:8

search 6:12

13:17,17 25:17

39:14

searched 9:8

second 39:1

40:12,17 48:19

48:21

seconds 35:8

section 37:2

sections 32:3

securing 31:1

see 7:17 8:5

16:1,4,11

19:18 27:11

33:20 39:6

49:10

seeking 13:8

seem 44:15

seemed 32:15

sees 40:11

seized 24:5

sense 15:9

33:21

sent 8:17,21

sentence 16:7

sentencing 30:4

separate 35:15

serious 38:17

serpe 41:12

45:1 48:10,12

FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 07/22/2026 OSCAR NO. 616139 -PAGE Page 67 of 70 * PUBLIC *

PUBLIC

Oral Argument

[servicing - sure]

servicing 39:10

several 23:20

share 15:16

37:13

shift 38:4

shocking 25:6

show 29:7 36:7

showed 25:19

showing 17:15

17:20 36:10

shows 22:18

sic 6:13 10:9

side 44:2

sides 11:13,14

38:15

signature 51:19

52:16

significant 42:3

45:12,14

silverstein 4:3

similar 33:5

40:19

simply 41:21

single 48:18

sir 6:3 8:8

six 28:13 36:13

36:20

skills 51:12

52:8

skipped 15:2

small 27:19,20

someplace

43:10

July 22, 2026

Page 15

something's

39:20 43:22

somewhat 26:2

sorry 6:7 12:11

14:17 15:5

16:2

sort 10:18 15:1

21:20 33:11

37:19 42:9,11

sought 45:16

sounds 8:2

source 26:4

28:7

sourcing 27:17

speak 8:19

44:20 49:19

speaking 7:9

8:22 9:2,3

specialists

16:10

species 48:19

specific 30:16

38:12 40:13

specifically

6:14 30:2

speculated

37:20

spite 41:11

sport 45:15

squarely 48:6

staff 8:15

standards

34:12

start 6:18

10:17 21:18

started 27:18

starts 39:14

state 30:6

statement

10:10 19:4,4

states 1:1 12:9

13:10 30:1

35:8

statute 10:8

22:3 30:4

stay 39:21

stayed 39:19

step 46:1

steps 8:1

stick 46:18

stop 13:14

straight 20:22

street 2:5,13

3:6

stretch 7:15

strictly 7:8

study 33:22

stuff 13:21

23:17 25:9

sub 18:6 19:11

19:13,14

subpart 19:5

subsequent

32:3

subset 29:21

30:16,16,18

www.CapitalReportingCompany.com

202-857-3376

substance 6:13

9:21 11:11

13:22,22 17:8

17:15 22:11,14

27:16 28:11,12

28:17 31:22

32:2 36:17

substances

9:11,13 10:2,4

13:9 23:3,8

26:4 29:3

43:16

substantial

36:10

substantially

31:21 32:11

substantive

34:11

suite 2:13 3:6

summarize

8:16 9:6

sunland 9:9

supplement

27:3

support 20:11

33:21 47:4

supporting

21:2

supposed 46:10

supreme 29:19

sure 9:7 13:3

16:17 23:13

27:9 34:8 39:5

FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 07/22/2026 OSCAR NO. 616139 -PAGE Page 68 of 70 * PUBLIC *

PUBLIC

Oral Argument

[susel - ultimately]

susel 4:6 15:16

suspect 42:18

suspension

40:4

suv 6:12

swear 19:8

switzerland

33:13

sworn 51:7

t 5:1

tack 24:3

tadesse 1:16

8:9 51:4,20

take 6:15 8:1

29:7 46:10

taken 31:20

33:6 51:5,14

52:11

talk 21:16

26:18,19 29:16

31:16 35:20

43:13

talking 31:10

42:9

teams 8:20

technical 29:2

29:13

tell 38:16 44:20

telling 25:7

ten 20:4

tension 15:9

16:13

July 22, 2026

Page 16

term 30:3,5

terms 29:1 30:6

30:17 35:9

46:8

testifying 51:7

text 20:1 27:15

thank 8:10

10:15 11:7

21:9 47:11,18

50:3,7,8

thanks 50:9

theme 21:20

theory 36:22

therapeutic

32:5

things 34:9

think 7:16,19

14:22 16:1,21

19:18 20:3,6

21:19,22 22:4

22:8,10 23:22

24:2,10 25:7

25:14 28:5

29:12,17,19

30:20 31:3

32:13,20 33:7

33:15 36:3,9

37:8,13,19

38:15 40:1

41:11,22 42:4

43:22 44:12

45:7,8,11,22

46:1,2,19,20

47:2,6,21 48:1

50:5

thinks 7:21

third 40:19

thought 28:3

41:13,18 43:12

44:1 45:16

three 11:10,12

17:16 22:13

time 1:11 6:2

21:6 35:19

37:16 38:18

39:11 44:11

50:10,11

times 9:1 32:6

today 8:15 9:1

10:11,20 38:1

42:11 44:4,13

47:20

today's 9:18

took 28:17

46:10,11

topic 28:3

touched 19:11

trade 1:2 4:4,6

4:8,11,12 6:6

transcribed 8:6

transcriber

52:3

transcript 8:11

52:5,7

transcriptionist

51:10

travels 43:4

www.CapitalReportingCompany.com

202-857-3376

traverse 36:5

treat 20:11,21

treatment

20:17 21:2

tried 38:2

trouble 29:8

true 51:11 52:7

try 38:4

trying 26:12

33:10

tulsa 2:6

turn 37:12

two 9:10,14,17

10:6 11:18

17:21 22:18

29:21 33:5

39:13 40:3,22

42:12,14,16

43:16 45:14

46:5

tying 20:11,17

typewriting

51:9

u.s. 12:21,22,22

13:12 14:1

15:6 18:9,11

18:17 19:6,22

30:2,10 34:13

u.s.c. 37:3

ultimately

13:10 23:15

FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 07/22/2026 OSCAR NO. 616139 -PAGE Page 69 of 70 * PUBLIC *

PUBLIC

Oral Argument

[under - yeah]

under 6:13

9:22 10:12

11:9 14:7

15:11 17:4,8

17:15 18:5

19:8 22:3 23:3

23:20 24:3

37:1,2

underlies 42:9

underlying

21:20

underscore

37:20

understand

14:21 23:16

24:5 25:12

understanding

13:20 19:5

27:18 29:6

understood

38:21

unfair 16:15

unit 2:10,12

united 1:1 12:9

30:1 35:8

universal 19:21

universally

20:12

unknowns

48:22

upheld 9:16

upward 45:5

use 6:10 11:21

14:6 16:8 17:2

July 22, 2026

Page 17

20:11,13 22:17

23:5,10 25:9

31:4 32:5,19

32:22 34:19,19

36:7

used 14:1,8

20:21 30:15

useful 43:12

uses 33:13

v 30:9

valid 20:13

vasodilator

12:3

vehicle 9:9

13:18

version 13:11

veterinary

11:21 15:6

16:9 19:6

20:13 22:17

23:5

video 7:12 9:1

videoconfere...

4:5,7,9,11,13

4:15,16

view 27:15

views 44:18

49:21

violating 28:19

violation 29:2

29:13,14

violations 9:15

9:18 39:12,17

40:3,22 43:16

43:17 48:4

virginia 51:22

vs 30:1

wada 31:20

32:12,15,17

33:1,7,7,11,12

34:2

wait 12:15

wallpaper 11:3

want 10:17,18

18:4 20:4,5

27:4,7 28:2

29:16 31:16

34:15 35:11

36:1 44:19

50:1

wanted 10:21

25:15 46:18

wants 30:15

washington

1:15

wave 7:22

way 12:5 24:17

45:1 49:18

we've 7:12 8:17

8:20 10:19

website 27:22

wedgewood

13:7,15,15

www.CapitalReportingCompany.com

202-857-3376

14:18 23:16,17

24:2,22 26:21

wednesday

1:10

welfare 2:10,12

wide 34:13

wild 37:4

withdrawn

22:21

withdrew 12:2

witness 51:6

word 29:18

30:15 35:7

43:4

words 26:15

work 45:3

works 13:21

31:3

world 31:19

32:11

worry 17:9

wrong 14:1

17:11

x 5:1

yeah 12:12

22:7 24:15

26:1,2 27:9,10

28:22 31:12

33:3,3 37:4

38:22 44:22

47:11

FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 07/22/2026 OSCAR NO. 616139 -PAGE Page 70 of 70 * PUBLIC *

PUBLIC

Oral Argument

[years - yep]

July 22, 2026

Page 18

years 12:5

yep 38:11

www.CapitalReportingCompany.com

202-857-3376

This is a copy of a public record, reproduced as it was published. It is not legal advice, and it may not be the version a court would rely on. Check the official source before you cite it.