and Wildlife Service and assisted by the U.S. Department of Agriculture, U.S. Customs Service and the then CITES authority in Peru (INRENA) among others, brought Kovach to trial. Kovach was sentenced to 2 years probation and a fine of $1000. While Selby Botanic Gardens saw its CITES permit revoked, was sentenced to a fine of $5000, and staff member Wesley Higgins received a 6-month restriction order. A nomenclatural proposal was put forward in 2006 to declare the name Phragmipedium kovachii invalid and to add its original ad hoc publication "Selbyana vol. 23 Supplement" to the “opera utique oppressa” (ICN Appendix VI). Counterarguments were presented in several articles. The Nomenclature Committee for Vascular Plants declined to accept the proposal, stating "if all names based on specimens illegally collected or named after persons who have acted unwisely ... were to be rejected, we might have some major nomenclatural instability." Distribution and habitat Phragmipedium kovachii is known only from a small area of five localities in the regions of Amazonas and San Martín, Peru. It grows in primary montane forest, at 1600–1950 (−2000) m of elevation, on limestone cliffs. The habitat of this species provides constant rainfall, organic matter and calcareous soil, with a pH of 6.8–7.1 (−7.9). Temperature in the area has an average of 26 °C in summer and 18 °C in winter; precipitation average is in the range of 1000–1500 mm (40–60 in). Ecology Phragmipedium kovachii grows in clumps of 15 to 20 individuals on cretaceous limestone cliffs facing south, in east-west oriented valleys. It is apparently a soil specialist since, unlike other Phragmipedium species, it prefers calcareous soils with an 85.7% of calcium carbonate content. Pollinators of this species are still unknown to science, but thought to be larger than in other Phragmipedium species, due to the bigger size of the lip. It is also hypothesized that the color pattern of the flowers mimics that of Tibouchina species, and helps attract pollinators that are sensitive to color. Conservation Overcollecting is a major threat to the survival of P. kovachii in the wild as it was found that one locality of P. kovachii was depleted of plants, possibly even before the scientific publication in Selbyana. Following the publication, other three localities were also overcollected. It is estimated that 5000 plants or more have been extracted from the wild. Despite its inclusion in Appendix I of CITES, there's criticism on the