Revenue Recognition We recognize revenue in accordance with Accounting Standards Codification 605,  Revenue Recognition-Products,  or ASC 605. Pursuant to ASC 605, we recognize revenue when we have persuasive evidence that an arrangement, agreement or contract exists, when each of the following three criteria are satisfied: (i) title for our product and risk of loss have passed to our customer, (ii) the price we charge for our product is fixed or is readily determinable, and (iii) we are reasonably assured of collecting the amounts owed under the resulting receivable. We do not require collateral from our customers. In the U.S., our exclusive customer for Acthar is a specialty distributor. For our sales to this specialty distributor, a sale of Acthar occurs when the specialty distributor accepts a shipment of Acthar based on its order of Acthar from our exclusive agent for commercial shipment of Acthar to the specialty distributor. We sell Acthar at a discount from our list price to the specialty distributor, which then sells Acthar primarily to approximately 12 specialty pharmacy companies and many hospitals. We provide free vials of Acthar, to support a patient assistance program administered by a third party administrator. We do not recognize any revenue or net sales from this program. Separately, we make charitable contributions, in dollars, to independent third-party charitable organizations which administer co-pay assistance programs. International sales of our products are immaterial. Net Sales We record net sales after establishing reserves for the following: " Medicaid rebates; " TRICARE retail program rebates; " Medicare Part D Coverage Gap Discount Program rebates; " Chargebacks due to other government programs; " Questcor-sponsored co-pay assistance programs; " Exchanges, which have historically been immaterial; and " Other deductions, such as payment discounts. We currently provide our products to Medicaid participants under an agreement with the Centers for Medicare and Medicaid Services, or CMS. Un