Clinical Cannabis Today November 2011 The Perfect Storm by Ben Fuller

November 2011

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Editorâ&#x20AC;&#x2122;s Letter

walked out my side door only to have it blown back in my face because of the incredible storm raging outside. After getting drenched by the onslaught of rain from the broken downspout right above the screen door, I took off running towards the car. Reaching my car Iâ&#x20AC;&#x2122;m instantly disappointed when I realized the window had been open during the entire storm, and knowing the wet pants awaiting me, I decided to sift through the fast food bags, coffee cups, and soda cans littering the floor of my car looking for something to dry my seat. I cover my seat with the plastic bag I found amongst the trash, sit, down and gloomily drive away into the storm leaving on my journey. Unlike the storm I faced a few weeks ago, newborn medical marijuana businesses are facing a different storm. They are getting soaked with regulation, while hearing tornado sirens in the distance from the federal government and as unpredictable and disastrous as lightening; various campaigns try to ban dispensaries, growers, and edible makers from their communities. 16 states, plus the District of Columbia, have medical marijuana laws on the books, and only a few of these states have seen industries develop. All of them have faced a storm just trying to get these laws passed, but they have not seen a lull in the storm since. States are fighting for their rights and these new businesses continue to fight battles never seen before. Our first issue of Clinical Cannabis Today takes a look at the storm boiling in the medical cannabis industry while introducing this new industry to the country. We write from a business perspective and want everyone to be informed about one of the newest, most controversial, and possibly lucrative industries in our country, the Cannabis Industry.

Volume 1, Issue 1

Marla Richards Publisher marla@clincialcannabistoday.com Kimberly Huntley Managing Editor editor@cctmagonline.com Ben Fuller Online Editor ben@clinicalcannabistoday.com Jason Gall Creative Director Jason@clinicalcannabistoday.com Ian Christensen Circulation Director Ian@clinicalcannabistoday.com Contributing Writers: Matt Cook - Matt Cook Consulting Micah Johnson - Cannapages.com William Knowlton - Foster Law Group Rob Heaton - Erupt Nutrients Steve Levine - Mission Mobile Clinical Cannabis Today is published six times a year and is a publication of: Holy Smoke Media, LLC http://holysmokemedia.com 13835 N. Tatum Blvd. Ste. 9-159 Phoenix, AZ. 85032-5582 (602) 315-8808 For comments, questions, or more information please contact: info@clinicalcannabistoday.com For Subscriptions please visit: http://subscribe.clinicalcannabistoday.com -orSend an e-mail with your name, address, and phone to: circulation@clinicalcannabistoday.com Subscription Cost: $59/year

Ben Fuller, Web Editor ben@clinicalcannabistoday.com

November 2011

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Contents

Volume1, Issue 1 NOVEMBER 2011

sections

features

banking

A FLOOD OF CASH?

With banks closing their doors to dispensaries, the only thing left for owners is a big pile of cash. What to do with all of this cash? Page.........................................8

MMJ banking is disappearing and cash is increasing By Micah Johnson...............................................................

THE STORM CONTINUES East Coast Medical Marijuana Part One By Ben Fuller.......................................................................

THE PERFECT STORM

Federal implications on several major issues By Matt Cook......................................................................

in every issue

news An in-depth investigation into states MMJ programs. What are the cases for success? Page.......................................20

legal Medical Marijuana raises issues in the workplace. The facts, the myths and the outcomes. Page.......................................22

editors letter...................4

green thumb

product showcase........26

The real cost of plant nutrients - A all to action for the environmental impact of nutrients. Page.......................................24

vendor spotlight...........30

premier issue 6

November 2011

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November/December 2011

A Flood of Cash? By Micah Johnson

Medical Marijuana states from around the country look to Colorado for its unique profitability from the multimilliondollar industry, even during a recession. But the last major bank shut its doors to dispensaries this autumn, and their once-optimistic operators now say it will be difficult to keep the accounting straight for the state’s new inspectors, not to mention the IRS. Will the flood of cash drown the industry?

n a brisk day in September, Luke Bonow made the drive up from Colorado Springs to a Bank of Denver location to open an account. He did his best to conceal two thick wads of cash, stuffed in envelopes in his pocket. The security guard smiled as he walked in. So did the lady at the information desk. He hoped the bankers would too, when he told them he needed a place for thousands of dollars from his medical marijuana center. Bonow did the same thing that hundreds of dispensary owners in Colorado did this past September: search for a bank account, of any kind. Colorado Springs State Bank, the last to assist dispensaries outside Denver, announced plans to close all current MMC accounts by the month’s end, meaning that in spite of nearly a decade spent stabilizing and taxing a multimillion-dollar cannabis industry, Colorado may witness its transition back to a cash-only economy. The situation has resulted in a strange sense of omertà. No dispensary owner with a bank account will “talk” details. The public, meanwhile, has been fed stories of suspicious, backroom agreements. But the reality is simple: with federal pressure from the U.S. Justice Department, national institutions who serve the cannabis industry have buckled under unspoken threats, and CSSB was the latest bank to go. Adilas is a Salida, Colo.-based company that aids MMCs with their point-of-sale and cultivation monitoring. Cofounder Steve Berkenkotter helps clients install a virtually paperless system that can summarize all transactions and accounting with a push of a button, including bank account reconciliation. But there’s hardly any point, he says, if the MMCs will just be stashing cash under their mattresses.

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“It’s not difficult for the system to track,” he says. “It’s difficult for the person to track. A bank account is a crucial part of any business. You can’t do without one.” Berkenkotter reports that of the 50 dispensaries he personally assists, nearly all are without a solution. New legislative rules enacted in July forced each MMC to find a system like Adilas, and start tracking every penny. For many of them, finding a bank also became paramount, as did finally straightening out the books. Bonow, the co-owner of an Altitude Organic Medicine dispensary in Colorado Springs, says he had no choice but to drive up to the bank himself. When he got to the information desk, he asked if he could open a dispensary account. The woman eyed him suspiciously. “No we don’t do that,” she answered. He sighed. He’d just driven over an hour. “If I’d called would it be a different answer?” She thought about this. “Wait a minute, and I’ll see,” she said, and disappeared into the back. A few

minutes later, a banker stepped into the lobby and explained that you couldn’t just walk through the door looking to open an MMC account. There’s a whole process, he said, starting with a referral and full review. “So,” Bonow asked, “even if I go through the process, do you take Colorado Springs dispensaries?” The man shook his head.“We’re still reviewing the option,” he told Bonow. “At the moment, we’re not authorized.” “When will you know?” “Tomorrow.” Bonow called back 48 hours later and spoke to the same associate. “We’ve decided not to take Colorado Springs accounts,” he said. “We can only help those in Denver.” Hanging up the phone, Bonow scratched his head. Was there any bank that would accept his wads of cash? *** Ever since Amendment 20 passed in Colorado, allowing the cultivation and sales of cannabis, dispensary

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November/December 2011

“really” wanted the dispensaries to find a bank, Bonow adds.“And I was thinking,‘No kidding, help us find a bank!’”

owners have been desperate to show the public every shred of legitimacy and willingness to play by the book. But when the number of registered patients skyrocketed in 2009, growers—some barely old enough to drink legally–would just stroll into supplystrapped dispensaries with backpacks full of marijuana in return for fistfuls of cash. The laws were so obscure at that point, lawmakers hadn’t prepared for such scandalous, unmonitored transactions, which became a focal point for those voting to ban the industry locally. The lack of financial oversight gave way to increased crime and worries that the system would actually usher in even more black market purchasing. So, by summer of 2010, caregivers were limited to five patients or forced to join with dispensaries. Around the same time, the Department of Revenue began accepting official rule suggestions from ACT4Colorado, a group comprised mainly of cannabis vendors. These rules, meant to remedy ambiguities in the amendment, required each gram to be tracked from seed to shelf. But it also required that the dollars and cents be reported with the same precision one might give an IRS audit. The “dollars and cents” are most important, at least, to the taxpayers. Colorado’s MMJ industry is different from that in many other states, in that the dispensary model is not nonprofit but rather regulated and taxed by the same office in charge of gaming and liquor. Employees must be “badged” and extensively background-checked. Patients go through an exam and licensing process that can take four to eight weeks and cost at least $150-$250. And yet the state paid off major debts this past year with collected patient fees. Another $2 million flowed in from sales tax, and many municipalities collect thousands each year in additional fees. What this amounts to is a potentially billion-dollar industry—vital to the current state budget—without anyone to issue the checkbooks. “A simple fix would be to just live in Denver,” Bonow joked after his ordeal. At least for the time being, the capitol city seemed the safe-haven for Colorado Springs wanderers. Rumored banks and credit unions had been taking care of the nearly 300 metro dispensaries there, for years. Throughout the summer, those dispensaries watched from the sidelines, with no real reason to unify and support the affected out-of-towners. “Right now, our strength is in our numbers,” says Tanya Gaurdano, president of the Colorado Springs Medical Cannabis Council, a group of cannabis businesses. The CSMCC notably became the only group to begin negotiating with other banks, not only because of their proximity to the situation, but due to lack of leadership from other organizations historically vocal on such matters. The Cannabis Therapy Institute,

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The meeting did, however, launch the CSMCC’s initiative to found and develop a bank, owned and operated by the industry. The idea is not new by any means, but has never gone much farther than speculation. With a rekindled momentum fueled by befuddled business owners, the option is now more a necessity than investment opportunity. “Ultimately, we have to form our own credit union,” Gaurdano explains. “That is the long-term goal, regardless of our short-term solutions.” “Long-term” is just one of many adjectives to describe what could take another decade. Twelve leaders would have to be picked by a unified and unbiased voting body large enough to represent a majority of the industry. These leaders would then have to find investors, and staff a board of directors with enough financial gurus to stay the course. But most of all, they would have to apply for the NCUA charter, essentially requesting ACT4Colorado, and the Medical Marijuana Business Alliance have all been absent on the subject.

and “knowingly facilitate such activities.” Arguably, the message sent a signal that institutions—even state governments—would be held accountable.

At the end of August, CSMCC thought they’d found a solution. A new agency promised banking solutions at good rates. Some dispensaries desperately and prematurely plunged into contracts with the credit card processor, hoping for quicker and broader assistance. The deal, though vague, was more promising than anything else on the table. But things fell through before a plan could be implemented. Negotiations fizzled, offers fell flat, and new bids were sought. With only weeks away from account termination, MMCs operating outside Denver were still completely in the dark. *** Financial institutions have been a major problem for MMCs since 2009, when banks began shutting dispensary accounts, especially those with blatant monikers. PayPal not only shut down any accounts remotely related with cannabis, they froze the funds. It wasn’t until large-scale institutions like TCF and Wells Fargo started closing accounts abruptly and without warning in 2010 that groups began flocking to the Colorado Springs Bank for lack of other options. Some would drive two hours each day to make deposits, even down mountain passes in the snow. The nail in the coffin came this past summer in a memo from Deputy Attorney General James M. Cole. While instructing U.S. Attorneys not to waste resources on compliant patients, Cole reiterated that cultivation of cannabis is still a violation of the Controlled Substances Act. The memo subtly hinted at possible prosecution for government employees who follow state mandate

Herring Bank, which owns Colorado Springs State Bank, does most of its business in Texas and Oklahoma, where cannabis is still illegal. The bank never released an official explanation for the account closures. Senior Vice President John Witten says the accounts simply became “too difficult to administer.” But MMCs were not the cause of the decision, and the bank’s professional relationships with those losing their accounts had always been up to par. “We’ve never had any direct problems with the medical cannabis industry,” Witten notes.

federal insurance on funds declared federally-illegal. Given the industry’s strange hiatus from unity, the task is daunting to say the least. But Guardano is determined that it’s the only true answer. “Our next bank could drop us six months down the road,” she says. “I don’t think we’ll feel truly safe until we have a credit union of our own.” *** Not everyone is in hot water, at least, yet. MMCs in outlying mountain towns have been spared at their local banks, but only because they’ve been graciously grandfathered-in. Diane Dunlap, who owns High Valley Healing Center in the small town of Crestone, says she’s thankful to still have her community bank, because she couldn’t run her MMC without the account. “I heard that some dispensaries are going to Walmart and buying debit cards to pay all their bills,” she says. “But that’s really stupid to me. Everything is much more track-able if you just have a damn bank account.” But sending a multitude of operators into the Rocky Mountains is out of the question. In a letter to the

CSMCC and other nomadic MMCs on Sept. 12, Gaurdano announced that a new man in charge, Jerry Brennan, was stepping in to develop a banking plan. Brennan is two-year member of the CSMCC, and works as a sales associate for Northgate Management Services, which represents several credit card processors. According to the letter, MMCs can go through Brennan’s office to sign up with Guardian Data Systems in order to get an official bank referral. To apply, a dispensary’s DBA, articles of organization, and operations must be fairly ambiguous, among other caveats. Gaurdano was quick to emphasize secrecy, saying “We’re afraid that if we publicize a bank’s agreement to work with us, they’ll be shut down just like the others.” But these referrals can mean higher rates and monthly fees. And the application process engages the same loopholes that allowed MMCs to get approved, then shut down, elsewhere. The only other solution offered, was the possibility that multiple-chain Californian banks just might accept out-of-state MMC applications, and that operators should make their deposits via “armored car” or “FedEx’d Cashier’s Checks.”

The decision isn’t breaking news, either. Bonow says he’d known about the impending account closure for about three months. “But we haven’t been preaching it to other dispensaries,” he says. “Our fear was that we’d act like a bunch of stoners and wait until the last minute to make a run on the bank.” Mounting panic from MMC operators finally prompted the CSMCC to hold an emergency meeting in August to discuss options. A representative of the Department of Revenue’s Medical Marijuana Enforcement Division was invited to answer questions. Bonow says he was not impressed. “I didn’t leave with any more reassurance. No questions were answered.” Someone from the audience asked if the industry could use a state-chartered bank, or even the actual one used for state employees. “But that question was never answered!” Bonow says. “ It was extremely frustrating.” The speaker told attendees the department of revenue

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November/December 2011

Many operators bit the bullet and went with the recommended referrals. Others returned to cash-only in the interim. Gossip went around about MMJ-friendly banks in Vegas, as did a swarm of new ATM vendors. The end of September came swiftly, and the accounts at Colorado Springs State Bank shut for good. The weather can change quickly and drastically in Colorado. As Autumn chills settled in, Gaurdano received good news that a local credit union had agreed to accept applications. “We’re crossing our fingers on that one,” she told inquisitors. But a flood of desperate applicants showed up, and seven days later, the option was out. Even more recent and shocking was news that Bank of Denver would be closing dispensary accounts by the end of the year. The announcement was made in mid-October and unleashed a nervous panic across the metro. Now, the last known safe accounts are through suburban credit unions that limit services to MMC’s in their specific suburbs. The entire fiasco threatens to put a squeeze on Colorado’s cannabis economy. Revenues could be lost. Black market supply could increase. And expensive

equipment, subscriptions, taxes, electronic bills and more would likely be funneled through other accounts, only exacerbating what already amounts to an IRS migraine. Meanwhile,ownerslikeBonowtrytocarryonwithbusinessasusual,buttheyaredesperate for direction.“We’re prepared to do everything with an ATM if need be, but that stinks,”he says.“We’ll do whatever we need to get a bank account. Sign up with a processor, anything.” Bonow admits that he only really uses the bank to make large purchases. But those expenses—like the electrical outfitting for a cultivation center—can cost tens of thousands and absolutely require check or card. The city of Colorado Springs charges thousands in annual license fees. And then there’s payroll. “It’s incredibly difficult to regulate a massive cash-only industry,” Bonow says. “There are huge problems with cash. We need a solution, now.” Contributing writer Micah Johnson is a senior editor at Cannapages.com, and manages two dispensaries in Denver.

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November 2011

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November/December 2011

The Storm Continues

East Coast Medical Marijuana Update By Ben Fuller

Delaware, Washington, D.C., New Jersey, Rhode Island, Vermont, and Maine are unique on the East Coast because they are the only states with medical marijuana programs. Currently 16 States, and Washington, D.C., have some sort of defense in court for qualified and registered patients who are growing and possessing marijuana. This is part one of a two part series investigating the medical marijuana programs across the United States. Delware The Facts

According to DelawareOnline, the Delaware government passed Senate Bill 17 on May 13, allowing patients to possess six ounces of usable marijuana, which could be purchased from a nonprofit dispensary, or from a caregiver providing care to no more than five patients. “Six ounces is less than the federal government has determined is a one-month supply for patients in the Compassionate Investigational New Drug Program,” says the bill. This bill acknowledges that the medicine will be purchased from dispensaries and caregivers, so patients and owners do not have to fear running into the problems that have arisen in Michigan “‘Registered compassion center’ means a not-for-profit entity . . . that acquires, possesses, cultivates, manufactures, delivers, transfers, transports, sells, supplies, or dispenses marijuana, paraphernalia, or related supplies and educational materials to registered qualifying patients.” The Delaware Department of Health and Social Services is charged with administering the program in the state. At this time, the department has not yet updated its site to reflect its new responsibilities nor is it collecting patient, caregiver, or compassion center applications. DelawareOnline reports that the DHSS does not have to start collecting applications until July 1, 2012. This means the soonest any patient could legally receive medicine is not going to happen before late 2012 or early 2013. If the normal delays for regulations take as long as in other states, it may take even longer.

Entrepreneur Lowdown

If you are thinking about jumping into the ground floor of a

November 2011

another open application period has not been set. Marijuana takes numerous input materials to produce, like soil, light, water and nutrients. These 15 businesses will have to compete against each other, paving the way for ancillary businesses making money providing advertising, management and other supplies and services. Millions of dollars are therefore at stake for all these new businesses serving the half million people in the District, and the thousands of potential patients. Big names such as Montel Williams have applied to be one of the businesses, says The Washington Post: “Williams says he has hopes to change perceptions about medical marijuana in Congress, but opening his clinic would come with a risk.” Entrepreneur Lowdown Since patients are not allowed to grow their own plants there isn’t a demand for grow stores, but doctors and clinics will likely start marketing to medical marijuana patients. The store fronts and grows will make a lot of money in Washington, D.C. because there are so few of them, and the thousands of potential patients have to purchase their all of the medical marijuana through them.

New Jersey The Facts

medical marijuana market, Delaware isn’t likely to be a giant gold rush like California and Colorado. It’s going to take time. No one can even apply until summer of next year, and it’s not likely you will be one of the three centers originally chosen. In addition, patients are not allowed to grow, according to ProCon.org—meaning even less business opportunity. Few businesses translates to fewer monies for advertisers, marketers and other business service firms, so the only real opportunity left is for doctors providing recommendations.

Washington, D.C. The Facts

More than 50 contenders have been approved to apply for a license to grow or sell medical marijuana in Washington, D.C. According to The Washington Post, only 15 businesses will ultimately be approved out of the 50, and the winners will be announced in early 2012. This news is welcome for a stalled medical marijuana program in the District. Amendment Act B18-622, was originally approved May 4, 2010, and went into effect on July 27, but no registration cards have been issued. Eligible patients are not allowed to grow but can possess up to two ounces of usable marijuana once registered. The District is using a model similar to Colorado, where 10 for-profit cultivation centers, or grows, and five stores will be licensed to operate, according to Cannabis Culture magazine. The deadline to apply to become one of the 15 has already passed, and w w w. c l i n i c a l c a n n a b i s t o d ay. co m

Governor Chris Christie recently allowed the New Jersey medical marijuana program to continue in his state after halting it to evaluate the federal government’s position on prosecuting employees in the industry. Earlier in the year, he halted the program due to worries about the federal government prosecuting employees within the program. On June 29, the Justice Department released a memo detailing its position on medical marijuana. The Wall Street Journal says, “it is likely not an efficient use of federal resources to focus enforcement efforts on individuals with cancer or other serious illnesses who use marijuana as part of a recommended treatment regimen consistent with applicable state law, or their caregiver.” Christie believes this means the very small and focused program in New Jersey will be outside of the scope that the Justice Department is worried about. But other states should worry because the memo also states that large-scale ‘commercial cultivation, sale, and distribution’ of pot for ‘purported medical purposes’ had expanded,

Governor Chris Christie recently allowed the New Jersey medical marijuana program to continue in his state after halting it to evaluate the federal government’s position. and the federal government never intended to ‘shield’ those types of activities from prosecution. New Jersey approved six nonprofit Alternative Treatment Centers for the medicinal marijuana program. The New Jersey Health and Senior Services Department announced the six centers on March 21, 2011. Patients are required to purchase their medicine from one of these six ATCs or from a caregiver who purchased it from a center. Neither they nor their caregivers are allowed to grow their own medication.

Entrepreneurial Lowdown

This budding, highly regulated program in New Jersey is not likely to go gangbusters soon. There are only six nonprofit centers selling product, but there are 8.7 million people in New Jersey,

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according to the latest U.S. Census Bureau Statistics. This would lead to a larger population base then Colorado, which could create even more patients. Colorado’s medical marijuana industry is valued at over a half a billion dollars, if not more, according to Cannapages. com. A lot of medicine, and therefore money, will be flowing through these six nonprofits.

Rhode Island The Facts

The Rhode Island Department of Health has had since June 21, 2007, to work out the kinks in its medical marijuana program setup in Senate Bill 710 and 791. It is now accepting patient applications and has chosen three nonprofit Compassion Centers. Patients will soon be able to designate any of these three Compassion Centers as one of their two caregivers. The rules in the state also allow a patient to possess up to 2.5 ounces of usable marijuana, and grow up to 12 plants, according to ProCon. org and the Rhode Island Department of Health. Story Continues On Page 28

November/December 2011

growers (manufacturers) or distributers (wholesalers). I am advised that retailers are spread throughout the state as collectives or cooperatives and that the number of them has created a need for a broadbased regulatory scheme.

he recent announcements by the federal government concerning potential enforcement action in California have the entire medical marijuana industry and the 16 states with enabling legislation (and the District of Columbia) wondering what will happen next. While cannabis remains a schedule 1 controlled substance pursuant to the Controlled Substances Act, and may be enforced by the federal government at any time, it is possible that the action of the federal government in California is the result of two key issues that may have created the perfect storm. California’s Enabling Statute In my opinion, California Health and Safety Code Section 11362.775 is as vague a statute as I have ever read during my 35-plus year career in government—and I strongly believe in the many arguments that the Tenth Amendment may provide for states concerning the issue of “states rights.” Section 11362.775 reads: Qualified patients, persons with valid identification cards, and the designated primary caregivers of qualified patients and persons with identification cards, who associate within the State of California in order collectively or cooperatively to cultivate marijuana for medical purposes, shall not solely on the basis of that fact be subject to state criminal sanctions under Section 11357, 11358, 11359, 11360, 11366, 11366.5, or 11570. While I am not much of a gambler unless the odds are significantly in my favor, my bet is that 10 fairly educated human beings could read, analyze and interpret Section 11362.775 and have 10 different interpretations pertaining to the issues of possession of marijuana and the ability to tax and regulate it, which is generally why states have these kinds of statutes to begin with. The famous “Ogden Memorandum” of 2009 clearly required “clear and unambiguous compliance with state law.” To refresh your memory, the following is an expert from the Ogden memorandum:

The prosecution of significant traffickers of illegal drugs, including marijuana, and the disruption of illegal drug manufacturing and trafficking networks continues to be a core priority in the Department’s efforts against narcotics and dangerous drugs, and the Department’s investigative and

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prosecutorial resources should be directed towards these objectives. As a general matter, pursuit of these priorities should not focus federal resources in your States on individuals whose actions are in clear and unambiguous compliance with existing state laws [emphasis added] providing for the medical use of marijuana. For example, prosecution of individuals with cancer or other serious illnesses who use marijuana as part of a recommended treatment regimen consistent with applicable state law, or those caregivers in clear and unambiguous compliance with existing state law who provide such individuals with marijuana, is unlikely to be an efficient use of limited federal resources. On the other hand, prosecution of commercial enterprises that unlawfully market and sell marijuana for profit continues to be an enforcement priority of the Department. To be sure, claims of compliance with state or local law may mask operations inconsistent with the terms, conditions, or purposes of those laws, and federal law enforcement should not be deterred by such assertions when otherwise pursuing the Department’s core enforcement priorities. Typically, when any of the following characteristics is present, the conduct will not be in clear and unambiguous compliance with applicable state law and may indicate illegal drug trafficking activity of potential federal interest: • unlawful possession or unlawful use of firearms; • violence; • sales to minors; • financial and marketing activities inconsistent with the terms, conditions, or purposes of state law, including evidence of money laundering activity and/or financial gains or excessive amounts of cash inconsistent with purported compliance with state or local law; • amounts of marijuana inconsistent with purported compliance with state or local law; • illegal possession or sale of other controlled substances; or • ties to other criminal enterprises. Of course, no State can authorize violations of federal law, and the list of factors above is not intended to describe exhaustively when a federal prosecution may be warranted. Ac-

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cordingly, in prosecutions under the Controlled Substances Act, federal prosecutors are not expected to charge, prove, or otherwise establish any state law violations. Indeed, this memorandum does not alter in any way the Department’s authority to enforce federal law, including laws prohibiting the manufacture, production, distribution, possession, or use of marijuana on federal property. This guidance regarding resource allocation does not “legalize” marijuana or provide a legal defense to a violation of federal law, nor is it intended to create any privileges, benefits, or rights, substantive or procedural, enforceable by any individual, party or witness in any administrative, civil, or criminal matter. Nor does clear and unambiguous compliance with state law or the absence of one or all of the above factors create a legal defense to a violation of the Controlled Substances Act. Rather, this memorandum is intended solely as a guide to the exercise of investigative and prosecutorial discretion.” Since the passage of 11362.775 in 2004, the general concensus amongst many of my collegues—lawyers and lobbyists— in California is that it is impossible to be in clear and unabiguous compliance with state law unless the law is understood. The exerpt from the Ogden memorandum uses the term “in clear and unambiguous compliance with state

law” five times. Section 11352.775 is anything but clear and unambiguous and may even make the genesis of a Tenth Amendment argument difficult. I was also advised that the California Attorney General’s Office recently issued “guidelines” concerning the implementation of 11262.775 and that the guidelines may not be uniformily imterpreted or applied by the courts throughout the state.

Matt Cook is the manager of Cook Consulting LLC that provides regulatory advice and public policy assistance to many states and industry members. Mr. Cook is also the architect of the Medical Marijuana Act for Colorado. This writing is an opinion only and is not to be intended as legal advice.

Lack of Consensus Second, consider the lack of concensus by both the industry and government statewide. California is one of the largest, if not the largest (watch out Florida) cannabis-producing state in the nation. Both state and local governments and the industry itself are divided as to their interpretation of Section 11362.775 and the need for regulatory reform. One part of the state wants limited enforcement, while other parts of the state want only to be

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However, the lack of any real concensus has bread indecision and, yes, corruption in the Golden State. My guess is that many local governments have became tired with a lack of general uniformity throughout the state and ultimately sought assistance from the Offices of the United States Attorneys and the federal government. But there is a silver lining in this cloud! While cannabis remains a schedule 1 controlled substance throughout the United States, subject to federal enforcment at anytime, broadbased enforcement in those states currently having a clear, thorough and unambiguous regulatory scheme may be an inefficient use of federal resources. At the time of this writing I am not aware of similar federal mandates being handed out in any other states and therefore, I have to ask, is this is really a national objective? If so, will it be accomplished one state at a time, or is their recent action more locally driven based upon the lack of clear and unambiguous compliance with state law. In addition, consider the potential impact on the 2012 national election and the potential to cause multiple states rights and commerce clause lawsuits: Could this be the beginning of the end, or the end of the beginning? The action of the federal government in California will be watched very closely by those states already having medical marijuana laws on the books as well as states contemplating new laws during the next election. In the interim, the need for a clear and unambiguous compliance with state law is critical. I do beleive that the Great State of California will get there—sooner rather than later. We all will have to wait and see what the next chapter brings.

November/December 2011

Marketing

Text Your Dispensary’s Message

wners of medical marijuana dispensaries can use messaging to market their products and differentiate themselves from their competition.

Short Message Service (SMS), or texting, builds on the growing popularity of mobile communications through the use of simple codes. The codes enable the business to push offers out to customers and prospects who have opted to receive the promotions, explains Steve Levine, president of California-based Mission Mobile.

A short code costs $500 a month from the carriers and the aggregators charge set-up and monthly fees, according to Levine. Cost to set up is about $1,500 to $2,500; monthly fees run between $500 to $1,500. By contrast cost from nothing to $250 for setup and $25-$250 in monthly fees. Messages costs are similar $.02-$.05 and can go down further with volume.????

Mobile marketing campaigns can be use to increase brand awareness, generate a customer opt-in database, drive up attendance to events or visits to a store, improve customer loyalty and increase revenues. The marketing can be done in conjunction with other media by placing “text [word] to [number],” Levine says. So for a medical marijuana dispensary with a special offer, the promotion might be “text offer to 12345.” The five-digit SMS services can be expensive, however, especially for a small business like a medical marijuana dispensary. Levine recommends looking at messaging services offering 10-digit SMS codes as an alternative. The longer codes, while more difficult to enter and remember, offer some distinct advantages:

▪ International accessibility

▪ Dedicated

▪ Low set-up and monthly fees

▪ Provisioned in one to five days

▪ Voice support

▪ Area codes available in most major markets

November 2011

“SMS messaging complements email lists and other marketing solutions,” Levine says. “With the flood of email that people receive, too many offers wind up in a spam folder.” While people don’t want to receive unsolicited texts either, by offering consumers the chance to opt in, they can get offers they could well be interested in, helping increase customer loyalty and retention. “All of the [medical marijuana] dispensaries offer weekly promotions,” Levine says. “Customers want to know about these promotions because they want to save money.”

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November/December 2011

Business

The Shape of Dispensing A quick look at MMJ ‘supplier’ models across the country By Micah Johnson

hen states decide to enact medical marijuana laws, they are given two immediate options: nonprofit or for-profit. Both have pros and cons. Nonprofits, for instance, don’t return revenues for the state and city like a forprofit industry. But the corporate model allows for modern business negotiation, capitalism and monopolies, many of which signal “organized crime” to locals who voted against medical cannabis in the first place. Here’s a quick look at a few types of these models from around the country.

the dispensary model, but they’ve still appeared in Seattle, where the industry is regulated by its members. Each store must mimic a true nonprofit entity, paying sales and business taxes in full. Currently, many groups act in members-only cultivation and production to supply the cannabis, but the future of for-profit entities remains, at this point, unlikely. Collectives Collectives are defined loosely; think hive mind. The group works as a whole to cultivate and supply cannabis to its members. Whether the collective chooses to form as a business in order to pay for costs or recoup losses, is up to them. Otherwise, the organization is prohibited from selling marijuana to nonmembers. One of the first collectives, Wo/ Men’s Alliance for Medical Marijuana of Santa Cruz in California, opened in 1993 and currently boasts over 250 members. Donations aside, each member is treated according to needs. California law does not define the collective structure, suggesting that either membership dues, or workload shared, make members eligible to receive the benefits of the crop. Members who work harder, though, can charge specifically for their labor and services. Some such groups charge a flat fee for a certain yield, and everyone shares in the harvest surplus.

NONPROFITS Cooperatives In California, Senate Bill 420 allowed for creation of both “cooperatives” and “collectives” as nonprofit suppliers of medical marijuana. Cooperatives must file articles of incorporation and are no different from their noncannabis counterparts; owners benefit mutually from the services they give themselves. Members can purchase the goods through retail atmosphere, or otherwise. Cooperatives are probably the best way to describe the state of Washington’s nonprofits. Governor Chris Gregoire vetoed

November 2011

In other states, the collective model is not so healthy. Montana’s cultivation gardens cannot be shared, for instance, which led to many “collectives” closing this past year with the partial enactment of Senate Bill 423. FBI background checks were due in October for all the lone caregivers still growing cannabis. Additionally, these caregivers can only have three patients, are legally restricted from taking even reimbursement for their costs, and they can’t advertise any services, which means that the collective ironically seems the best model to work within Montana’s restrictive laws. State-Appointed Nonprofits In 2010, Maine both established a registry and began developing a dispensary system. One nonprofit dispensary will open in each of Maine’s eight public health districts, and the Maine Department of Health and Human Services has

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licenses held by Northeast Patients Group, which plans to open its Portland, Bangor, and Augusta stores by the end of the year. The group is primarily financed by former NBA player Cuttino Mobley. Next door in Vermont, which just saw Senate Bill 17 signed into law this past summer, there are only four licensed nonprofit dispensaries. Each can serve up to 1,000 patients, posing the question: what if more than 4,000 patients get licensed for medical marijuana in Vermont? The state is sticking to the initially proposed limit of four centers, but fewer than 400 patients are currently registered, so there’s no rush to amend the bill. New Jersey is setting up a unique version of nonprofits, called Alternative Treatment Centers, which are akin to state-appointed neo-pharmacies. While for-profit centers will be eventually licensed, the first six must be appointed nonprofit locations, equally distributed across the state. Thereafter, applicants may apply to open a for-profit center, but with a significant risk: unlike states where a patient may purchase up to 2 ounces daily, New Jersey’s limit is 2 ounces per month, which may prove completely unprofitable to suppliers. Compassion Clubs After Governor Brewer filed a lawsuit demanding that U.S. District Court confirm the legitimacy of Arizona’s marijuana laws, the state’s dispensary applicants have been waiting for the green light. What popped up in the meantime—fueled by the vocal and politically powerful investors of the Consiglieri Group—are Compassion Clubs, created through a loophole, and unique to Arizona. These compassion clubs require an initial membership fee and successive donations. This is because, under Arizona law, patients who get cannabis from other qualifying patients must not pay for it. Compassion club operators swear they’re operating legally, but the donation system is still a legal gray area. In order to make the centers seem more like clubs, those like the Consiglieri group have gone to lengths to bring in live entertainment and other services like massage and acupuncture to their “2811 Club” centers. The state filed suit in August to shut down the clubs, and hearings are pending.

FOR-PROFIT Dispensaries Commercial dispensaries operate differently from nonprofits. Although patients still have to designate a dispensary to become a “member,” the membership really applies only to the growing of their plants. In Colorado, that’s six plants every four months, which allows medical marijuana centers to sell the surplus, if there is any, to nonmembers at a higher price. Prices were seen as high as $600 per ounce of high-quality cannabis in 2009; that number has since dropped to an average of $200. Retail operations have recently been shut down in Michigan, as both state and city officials question the legality of commercial cannabis, given the ambiguity of the original law. In late August,

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Colorado’s for-profit model is the only one successfully using taxes on cannabis to support the bureaucracy required to regulate it. the Michigan’s Court of Appeals declared cannabis sales illegal. So patients must go strictly to caregivers for their medicine. But caregivers are individuals and can’t hedge against a bad crop; they don’t always have a supply of cannabis for their patients. Very few donation-based nonprofits still operate in the state, and patients are mostly left to fend for themselves, or find someone to do it for them. The time and resources required to actually cultivate cannabis safely and correctly can be costly. Inexperienced growers can take four months to produce meager plants with small yields, suggesting that only dispensaries can be depended on for quality and supply. This was true for more than 100,000 Colorado patients until this past summer. When regulations forced Colorado dispensaries to produce 70 percent of their own medicine, patients statewide saw a drastic drop in both quality and supply. Some centers shut, unannounced, with nothing to sell on the shelves. The result is that patients have become disillusioned, as have dispensary owners themselves. Otherwise, Colorado’s for-profit model appears to be a beacon for other states, in that it is the only one successfully using taxes on cannabis to support the bureaucracy required to regulate it. The state has reaped millions in new revenues, partly from an explosion of centers in 2009. But the free market is still at work, and those inexperienced, under-capitalized centers that couldn’t keep up are starting to disappear. Contributing writer Micah Johnson is a senior editor at Cannapages.com, and manages two dispensaries in Denver.

November/December 2011

Legal

Medical Marijuana Raises Workplace Issues By William R. Knowlton, The Foster Group

arijuana is still classified as a Schedule I narcotic (and, therefore, illegal) under the federal law known as The Controlled Substances Act. However, in recent months, 16 states and the District of Columbia have approved the sale of marijuana to licensed patients. As of March 1, 2011, another 12 legislatures have proposed legislation permitting medical marijuana use. This is in direct response to the October of 2009 letter from the Justice Department, which stated the Obama Administration’s preference that U.S. District Attorneys not prosecute purveyors and users of medical marijuana acting in clear compliance with the requirements of state law. This clear conflict between state and federal law will not likely be resolved in the near future, creating a tremendous amount of uncertainty for employers who employ legal users (under state law) of medical marijuana. For example, a federal judge in Michigan recently ruled that Wal-Mart could terminate employees who tested positive for marijuana—despite the employees having a state issued medical marijuana card. The employee was not under the influence while working at Wal-Mart, but was involved in an accident on the job and required to submit to a mandatory drug test (as per the company policies). There were trace amounts of marijuana in his system and he was terminated. In another instance, the Washington State Supreme Court recently upheld a company’s decision to fire a woman for failing a mandatory drug test due to marijuana use, despite her having a valid state medical marijuana permit. What is an employer to do? Even in the face of ambiguity about the federal government enforcement policy, an employer still has a duty to comply with state law regarding medical marijuana. Also an employer needs to consider the implications of the Americans with Disabilities Act (ADA) and Family Medical Leave Act (FMLA) when dealing with an employee who is currently using medical pot as part of their medical treatment. The various medical marijuana laws vary from state to state—with many states looking to amend their current medical marijuana laws to provide more robust protections for employees— but as a general rule of thumb, Arizona’s medical marijuana law is as close to a model as anyone can find.

while on the job—regardless if the impairing substance is marijuana. More importantly, if the employer is engaged in an industry that is inherently dangerous (think commercial trucking, airplane pilots, operators of heavy machinery), the employer has an affirmative duty to ensure their employees are not impaired on the job (as failure to do so could subject them to serious legal and financial liability). Most experts agree that trace amounts of marijuana remain in a person’s systems long after their initial use the substance. And these trace amounts are detectable in almost every standard drug screening test—even days after using marijuana. The big question for employers is what to do if a non-impaired employee tests positive for marijuana during a mandatory drug test. The answer depends on where you live, as the examples Michigan and Washington above illustrate. However, in Arizona, unless an employer runs the risk of losing monetary awards or licensing under federal law, an employee should not be terminated for testing positive for marijuana during a mandatory drug test. Regardless of the state you live in, every employer needs to have a robust drug policy in place, particularly so if you work in an industry that is inherently dangerous. Also, the ADA prohibits an employer from discriminating against an employee (or interviewee) based on a recognized disability. It is highly recommended that employers modify their anti-discrimination policies to account for people who are using medical marijuana to treat medical conditions. This anti-discrimination policy not only applies to current employees, but also to prospective employees. In an abundance of caution, it is worth the few hundred dollars to consult an experienced employment attorney about these issues, as the potential liability could be in the hundreds of thousands of dollars for failing to properly address these issues. William R. Knowlton is a Tempe, Ariz.-based business attorney with The Foster Group, which has law offices in Arizona, Indiana, Nevada, and California. More: www.fosterslawgroup.com.

First, as with any substance that alters a person’s cognitive abilities, employers do not have to make accommodations for the use of medical marijuana in the workplace. Second, an employer can terminate an employee for being impaired

November 2011

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Green Thumb

The Real Cost of Plant Nutrients - A Call To Action

he cost of what you pay online or at the counter for plant nutrients (all of which eventually makes its way does not end there by a long shot—the real costs go much deeper. back to our waters one way or another). Agriculture and horticulture are among the most harmful activities Across the nation, that’s 910 billion galengaged in by man for the devastating effects on our ecosystem. Acceler- lons of water per year, a significant majority of which makes its way ated eutrophication resulting from plant nutrient leaching is the reason. through our sanitary treatment facilities. It is estimated that the Total Of particular concern are two nutrients essential for garden and crop Annual Economic Cost to treat that volume of water annually for the removal of phosphorus to acceptable growth: phosphate-phosphorus and remedial levels (0.5mg/L) would be nitrate-nitrogen. When leached, both $118.3 billion dollars and require more of these nutrients make their way into than 24 purpose-built systems within our lakes, rivers, streams and oceans, existing water treatment facilities cacausing intense algae growth—most pable of processing 100M gallons of notably, cyanobacteria, or blue-green wastewater per day per facility system. algae—leading to accelerated “eutroEvery taxpayer would pay these costs. phication” of our waters. In this process, excessive organic matter builds up as the THERE IS HOPE algae die and decompose, depleting the It’s really simple. Our first call to acwater of available oxygen to levels less tion is to minimize the emissions of than 2ppm. Oxygen depletion to that problematic nutrients at the source. extent causes serious harm and evenNutrient companies such as Erupt Plant tually death to all aquatic life present Nutrients are using new technologies to in the area, further fueling the oxygensupply plants based upon plant demand starved condition creating dead zones. for nutrition. Using a patent pending nano-technology, Erupt encapsulates DEAD ZONES The Gulf of Mexico dead zone covers The Mississippi River Delta (top photo) clearly de- nutrient ions like phosphate-phosan area ranging in size from 6,000 to picts the very large area affected by eutrophication. phorus and nitrate-nitrogen, hold7,000 square miles and originates Among the other regions affected are the Yangtze Riv- ing them harmless to the environfrom the mouth of the Mississippi er and the Pearl River Delta in China (below photos). ment while being plant accessible. River. The affected area starts from The result is up to 90 percent less nutrient leaching into the environment, the inner and mid-continental shelf in the northern Gulf beginning at the as reported by clinical trials (research paper available upon request). Mississippi River Delta and extending westward to the upper Texas coast. Other considerations would be to treat effluent from hydroThis is a global problem and these dead zones are increasing in size annually. ponic grow operations at the source and reduce harmful nutrient content in the effluent to remedial levels—putting the onus HIDDEN COSTS OF NUTRIENTS The environmental cost of this manmade toxicity is virtually immeasur- on the hydroponic grower to achieve a certain performance levable, and the cleanup costs are profound. As reported by the EPA, the el. Yes there is hope, but it is very dependent upon our actions. Obama administration committed nearly $500 million in 2010 to the Robert Heaton, M.Sc., Erupt Plant Nutrients, P.O. Box 508, Pickering, Ontario Great Lake Restoration Initiative alone—a mere pittance as compared L1V 2R7, Canada; to what is really required from both the United States and Canada. rob@eruptnutrients.com. Other notable initiatives reported in the EPA document included $4.3 billion for Clean and Safe Water and $814 million for Compliance and Environmental Stewardship. According to the U.S. Geological Survey, water use in the country is down slightly to approximately 80-100 gallons per person per day; or on the low end 29,200 gallons per person per year 24

November 2011

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CannaLine Jars

www.CannaLine.com When cannabis is stored in plastic, such as bags and pop-top jars, THC is pulled from the buds like magnetism. This underscores the need for glass storage--and presents a hidden opportunity to create merchandise with long-lasting utility. CannaLine’s customize-able jars have helped brand clients like Harborside Health Center and The Farmacy. Plus, their online platform makes it as easy as creating a personalized greeting card.

TRIMPRO

www.trimpro.ca

1 Case (64) 1/8oz Jars Customized from $124.80

The proverbial wisdom is that a $1000-dollar bud-trimmer is too cheap, while $2000 is much more than the machine is worth. Enter Trimpro, a quiet and luxurious machine that fits right in the price-pocket. The Canadian company has been pushing hard into the industry with several trimmers, all of which remove excess leaves and stems. Picky patients may argue that quality is lost, but gardeners who actually harvest by the pound will tell you there’s no other way to manicure it all. Original Standard Model from $1,434.99

Dixie Botanicals

www.DixieElixirs.com Already a leader in non-smokable medical marijuana-infused products, Dixie Elixirs & Edibles added Dixie Botanicals Therapeutic Bath Salts, Massage Oil, and Pain Relief Salve to their popular product line up. These all-natural transdermal products are formulated using a proprietary blend of oils including rosemary and cedar oils along with sativa-dominant cannabis to provide relief to a variety of ailments. For many patients, transdermal applications of THC are an effective method of relief for arthritic and rheumatic pain. The herbal blend, combined with the THC also provides deep relaxation for tired and sore muscles and has natural antibiotic properties, which may be effective against eczemas, psoriasis and fungus.

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November/December 2011

Liquid Ladybug Spider Mite Killer http://www.spidermitekiller.com

Quality control at grow facilities doesn’t end with mildew and mold; stop spider mite infestations in an eco-friendly way with Liquid Ladybug. The mixture is made of aromatic plant oils that are safe for both cannabis and gardener. Once covered, mites are overtaken as the oils seep into their respiratory system and organs, dissolving them from the inside-out. The company’s website also explains how to build “Mite Shields” to fend off the nasty little bugs. 16oz Spray From 19.95, One Gallon from 199.95

Sherlock Kief Box www.sherlockbox.com

Kief, the THC-filled trichomes that cover cannabis, can be sold for big bucks in concentrated form. But it can be difficult to collect, especially at the budtender level. Sherlock Box offers two extremely efficient contraptions to gather the pollen (commercial operations may love the larger Branyan model). Combination humidor and kief collector, its magnetic seals also miraculously prevent odors with cannabis stored inside. The Quintin from $79.99 or Branyan from$89.99

ADVERTISING INDEX GrowBot................................................................ 2,3 ~www.GrowBot.com~ MJ Freeway............................................................ 5 ~www.MJFreeway.com~ Dixie Elixirs............................................................. 7 ~DixieElixirs.com~ New York Life......................................................... 9 ~www.TGWatkins.com~ Clinical Cannabis Today.......................................... 12 ~www.ClinicalCannabisToday.com~ Cannapages.......................................................... 13 ~www.Cannapages.com~ Velstar.................................................................... 19 ~www.Velstar.com~ Mission Mobile....................................................... 23 ~www.MissionMobile.com~ American Cannabis Institute................................... 27 ~www.ACI-US.org~ Clinical Conference on Cannabis Therapeutics and Patients Out Of Time.............................................. 29

The AtmosRx

www.atmosrx.com Uniquely built, the AtmosRx is somewhat larger than eCigarette-sized vaporizers, equipped with lithium power and 100-200mg THC per cartridge, depending on the model. To enhance the experience, OrganaLabs announced earlier in the year that both flavored and herbal blends are forthcoming. Although patients still can’t choose between indica and sativa, they can medicate in theatres or hotel rooms with this odorless and discreet apparatus. Comes with wall/USB Charger and works with the push of a button.

Vapor Genie

www.vaporgenie.com In the old days, a vaporizer implied a bulky machine with a big balloon (which made a nice addition to the closet junk pile). But those days are over. VaporGenie is a great on-the-go vaporizer that looks and feels like a pipe. A lighter is required--heat is applied to the ceramic filter above the cannabis, which protects it from burning. Plus, its durable design prevents breakage, a rare perk from a high-priced smoking accessory. Classic Designs Start at $55

Retail from $99.95 ~ Cartridges from $13.95

November 2011

Velstar Sip IQ.......................................................... 31 ~www.Velstar.com~ Erupt Nutrients....................................................... Back Cover ~www.EruptNutrients.com~ w w w. c l i n i c a l c a n n a b i s t o d ay. co m

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November/December 2011

East Coast Medical Marijuana Breakdown Name Of No. Stores Nonprofit/ Patients Estimated No. Can Distributing Storefront For Profit Of Patients Grow To Patients Distributors Deleware

Compassion Centers Nonprofit

897,934

Washington, D.C.

Dispensaries For Profit

599,657

Nonprofit

8,707,739

Alternative Treatment Centers

New Jersey

Rhode Island

Compassion Nonprofit Centers

Yes

3,700

1,053,209

Vermont

Dispensaries Nonprofit

Yes

355

621,760

Maine

Dispensaries Nonprofit

Yes

250

1,318,301

Continued From Page 15 Entrepreneur Lowdown

Grow stores, nutrient suppliers, and basic input material providers are likely looking at Rhode Island as a potential customer base. According to RIPatients.org, more than 3,700 patients are already in the state, but regulation and lack of medicine is preventing Rhode Island from becoming a major player in the medical marijuana industry.

Vermont The Facts

The Vermont medical marijuana program started July 1, 2004, and allows patients two mature plants, seven immature plants, and 2 ounces of usable marijuana. Seven Days Vermont reports that in June, the state passed a bill allowing four nonprofit medical marijuana dispensaries in the state. The governor has held up the licensing of only the centers originally chosen to sell medicine in the state due to fears of prosecution of the employees. When the dispensaries finally open, they are limited to 1,000 patients each. Patients must designate the facility as their caregiver if they decide to use it, but this means they can no longer grow their own plants. The facilities must operate by appointment only, and no medicine can be consumed on the premises.

Entrepreneur Lowdown

It has already been seven years since Vermont removed criminal penalties for registered medical marijuana patients, but only 355 patients exist in the state, accordingtoSevenDays. Untilthepatientbaseincreasesandthestategovernment opens the dispensaries, it’s unlikely many businesses will explore Vermont.

State Pop. 2010 Census

November 2011

Maine The Facts

Eight dispensaries have opened in Maine this year as a part of its Medical Marijuana Program, according to the Providence Journal. These nonprofit dispensaries are located in each of the eight districts in the state, and are heavily regulated by the state. Maine’s program was introduced in December 2009, and patients are protected from criminal penalties while possessing up to 2.5 ounces, growing three mature plants, and growing three immature plants. Patients visiting from other states are protected under Maine’s program as well, reports ProCon.org.

Entrepreneur Lowdown

The State’s Licensing and Regulatory Services Site says no new dispensaries are planned, but more may be allowed in the future. The low number of patients estimated at only about 250 according to Procon.org, means that there will be few medical marijuana businesses within the state. Next issue we will continue with part two of this story featuring the remaining medical marijuana states. Ben Fuller, is online editor for Clinical Cannabis Today, web master of Cannapages.com, and maintains a number of other cannabis industry web sites.

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November/December 2011

Don’t Wait Until It’s Too Late....

Advertorial Cannapages.com provides new services to MMJ companies. Cannapages.com, Colorado’s most integrated cannabis technology firm, has rolled out new products and services for Medical Marijuana providers. Following the announcement of their partnership with local cannabis-testing group, Herbal Synergy, the company has swiftly unveiled new and unique solutions to the cannabis industry, including productbranding, photography, customized websites, and live online menus. The new solutions are meant to be the next step in the evolution of the modern cannabis dispensary, according to Chief Technology Officer Ben Fuller. “No one could have foreseen the technological demands created when the Medical Marijuana industry launched,” he said. “Our agency customizes today’s technology to adapt and integrate seamlessly with such a unique business model.”

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Fuller added that nearly all compliance issues can be resolved through Cannapages, from the video camera systems now required in dispensaries, to the software tracking cultivation centers, payroll, and accounting. But marketing is also a focus of the new initiatives, providing iconic and signature branding, merchandise and advertising for dispensary operators and their products. Cannapages.com began in 2009 as one of the first online MMJ directories in the nation. Employing a small number of patients, volunteers and industry professionals, the agency has expanded to offer tech and quality-control consulting. Throughout 2010, Cannapages started offering ancillary services like CannaMerchant (with partner Adilas), product labels, and CannaVideo, quickly becoming a one-stop shop for growing MMJ enterprises. The company now supplies websites for the National Cannabis Industry Association, and similar non-profits, activists, political campaigns, and private Medical Marijuana lobbying groups. Cannapages also provides ongoing tech and content for Clinical Cannabis Today and Cronic Magazine among other media outlets.

Our Mission is to help our client’s honor their patients and partners trust while maximizing their business success and personal freedom by cost effectively harnessing technology to: -Build safeguarded transparency into their business which will result in strong trust based relationships with patients, partners, employees and regulatory agencies -Maximize profits by implementing monitoring and controls that minimize time, utilities, material and inventory costs, improve crop yield and maximize quality -Improve sell through rates by optimizing inventory and pipeline control -Ensure regulatory compliance without adding costs Free Professional Install & Free System. Limited Time Offer While Supplies Last. Only Home & Business Owners Qualify For A Free System. Renters: We can ship you a system to secure your home as well.

November 2011

“We help our clients grow successful businesses that honor the trust put in them.” Creating a Win, Win, Win situation. Purposeful with integrity, for you, your customers and everyone the company touches.

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November/December 2011

November 2011

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