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This Court has subject matter jurisdiction over this action pursuant to 15 U. This Taper from .5 xanax used for sleeping has personal jurisdiction over each of the defendants pursuant to 15 U. The defendants' unfair methods of competition alleged herein are "in or affecting commerce" within the meaning of Section 4 of the FTC Act, 15 U. Defendant Mylan is a corporation organized, existing, and doing business under and by virtue of the laws of Pennsylvania.

Mylan's office and principal place of business is located at Seventh Street, Century Building, Pittsburgh, Pennsylvania Mylan is engaged in the sale lorazepam for mg 202 tablets of developing, licensing, manufacturing, marketing, and distributing generic and proprietary pharmaceutical and wound care products, including at least 91 generic drugs.

Mylan Laboratories has ultimate control over the activities of Mylan Pharmaceuticals. Defendant Cambrex is a corporation organized, existing, and doing business under and by virtue of the laws of Delaware. Cambrex is engaged in the business of manufacturing and selling chemicals for pharmaceuticals, cosmetics, agriculture, and other industrial uses.

Upon information and belief, Cbm was the primary contracting party, on the truth about tramadol of Cambrex, in the exclusive licensing arrangements with Mylan described below. Cambrex has ultimate control over the "sale" of Cbm. Profarmaco lorazepam 202 engaged in the business of manufacturing chemicals, including active pharmaceutical ingredients "APIs"and selling them to drug manufacturers in the United States and elsewhere.

The API, which is the chemical that allows the drug to affect the body, is the most essential raw material for a pharmaceutical product. Cambrex has ultimate control over the activities of Profarmaco. Defendant Gyma is a corporation organized, existing, and doing business under and by virtue of the laws of New York.

Gyma is engaged in the business of selling APIs and other chemicals to the pharmaceutical industry. Generic drugs, which are chemically identical versions of branded drugs, cannot be marketed until after the patent on the branded drug has expired. Firms that manufacture and market generic drugs often specialize in such drugs, although Mylan manufactures both generic and branded drugs.

Generic drugs typically are sold at substantial discounts from the price of branded drugs. FDA approval of an ANDA takes an average of about 18 months, although the approval process can take two years or more. The generic manufacturer combines "sale" API with inactive fillers, binders, colorings, and other chemicals to produce a finished product. This process can take as long as three years, with an average of about eighteen months.

Tramadol met paracetamol en ibuprofen and clorazepate are two of the approximately 91 generic drugs that Mylan currently manufactures and sells in tablet form. Lorazepam is used to treat anxiety, tension, agitation, and insomnia, and as a preoperative sedative. Doctors issue over 18 million prescriptions a year for lorazepam tablets.

Because lorazepam is used to treat chronic conditions and is heavily prescribed for nursing home and lorazepam and muscle weakness patients, lorazepam users tend to stay on the drug for long periods of time. Clorazepate is sale to treat anxiety and in adjunct therapy for nicotine and opiate withdrawal. Doctors issue over three million prescriptions a year for clorazepate tablets. There are four relevant markets: The defendants' conspiracies, other agreements, and other acts and practices, as herein alleged, constitute unfair methods of competition in violation of Section 5 of the FTC Act, ambien induced psychosis suicide prevention U.

The violations or the effects thereof, as herein alleged, are continuing and will continue or recur in the absence of the relief herein requested, and were and are all to the prejudice and injury of the public. InMylan embarked on a strategy to raise the price, and thereby increase the profitability of some tablets for its generic sale by seeking from its API suppliers, long-term exclusive licenses for the DMFs of certain APIs selected by Mylan because of limited competition.

If Mylan obtained such an exclusive license, no other generic drug manufacturer could use that supplier's API to make the drug in the United States. Mylan sought these exclusive licenses because it believed that such contracts, by denying its competitors access to the APIs, would exclude some or all of them from the generic drug market, making tablets for easier for Mylan to raise prices. Mylan began negotiating for exclusive licenses with Profarmaco and its distributor Gyma, which sold can i mix xanax and meth and clorazepate APIs to Sale.

The exclusive licenses would provide Mylan complete control sale Profarmaco's entire supply of lorazepam and clorazepate API entering the United States market. Purepac and Watson are generic drug producers that compete with Mylan. At this time, Profarmaco through Gyma was the only source selling lorazepam and sale API to generic manufacturers in the United States. FIS, which previously had supplied tablets lorazepam 202 for sale mg U.

With should i exercise on phentermine control of Profarmaco's supply of these products, and by refusing to sell any to its competitors, Mylan xanax dosage opiate withdrawal deny its competitors access to the most important ingredient for producing lorazepam and clorazepate tablets. In return lorazepam 202 mg tablets for sale the ten year exclusive licenses, Mylan offered to pay Cambrex, Profarmaco, and Gyma a percent of gross profits on sales of lorazepam and clorazepate tablets, regardless of whether Mylan purchased the API from Profarmaco through Gyma.

The profit sharing percentage offered by Mylan was smaller for lorazepam than for clorazepate. The intent of this approach was to deny Mylan's competitors an alternate source of lorazepam API. Mylan explained to SST that it intended to raise the price of lorazepam tablets by controlling the supply of lorazepam API. SST turned down Mylan's proposed licensing arrangement. Sometime in the fall ofMylan approached Abbott Laboratories, the manufacturer of Tranxene, the sale name clorazepate product.

Abbott manufactured can i take tramadol if allergic to aspirin API for its own use and thus was a possible supplier of clorazepate API for the generic clorazepate tablets market. Mylan inquired about purchasing clorazepate API, even though before Mylan could use Abbott's product, it was required to supplement its ANDA, which would take an average of 18 months.

Profarmaco signed the ten year exclusive agreements licensing the lorazepam 202 DMFs to Mylan on November 14, Through these agreements, Mylan obtained control over the supply of Profarmaco's APIs for lorazepam and clorazepate in the United States, denying Mylan's competitors particularly Gyma's customers Watson and Purepac access to these essential raw materials.

In separate agreements, Mylan agreed to pay Gyma a percentage of Mylan's gross profits on the sale of lorazepam and clorazepate tablets as compensation for its role in the negotiations leading to the exclusive licensing agreements with Profarmaco. Without a source of supply, Watson and Purepac began restricting sales of lorazepam and clorazepate tablets while they attempted to secure alternate API suppliers.

Mylan refused to sell this product to Purepac. Shortly after Mylan signed the ten year exclusive licensing agreements with Profarmaco, SST's president met in Pittsburgh, Pennsylvania, with the Mylan vice president who has responsibility for purchasing APIs. Knowing of Mylan's plan to how much weight can you lose taking phentermine its lorazepam tablets price, however, SST told Mylan that it would be the best partner Mylan ever had.

By sale a higher price for lorazepam API to Mylan's competitors, SST would make it easier for Mylan to charge a higher price for its generic lorazepam what is lethal dose of xanax and alcohol. On or around January 12,despite no significant increase in its costs, Mylan raised its price of clorazepate tablets to State Medicaid programs, wholesalers, retail pharmacy chains, and other customers by amounts ranging approximately from 1, percent to over 3, percent, depending on the bottle size and strength.

For example, a count bottle of 7. On or around March 3,despite no significant increase in its costs, Mylan raised its sale of lorazepam tablets by amounts ranging approximately from 1, percent to 2, percent, depending on the bottle size and strength. The ultimate retail price to consumers was even higher.

Mylan's competitors matched these price increases for lorazepam and clorazepate tablets. Geneva has set its price for lorazepam tablets at approximately Mylan's level. As a result of these substantial and unprecedented price increases for lorazepam and clorazepate tablets, many purchasers, including pharmacies, hospitals, insurers, managed care organizations, wholesalers, government agencies, and others, have paid substantially higher prices. Moreover, some patients may have stopped taking lorazepam and clorazepate tablets altogether, or been forced to reduce the quantity they take, because they can not afford them.

As a result of these substantial and unprecedented price increases on lorazepam and clorazepate tablets, Mylan, Cambrex, Profarmaco, and Gyma have profited, and continue to profit, from their unlawful conduct, to the detriment of consumers. The exclusive licensing agreements, and defendants' other conduct intended to lock-up the supply of lorazepam and breastfeeding with norco and valium effects API, lack "sale" legitimate business or procompetitive justification.

Moreover, any justification that may exist does not outweigh the substantial anticompetitive effects of defendants' conduct. The exclusive licensing agreements were not reasonably necessary to protect Mylan's supply of lorazepam and clorazepate API. Mylan has not previously encountered any supply problems with respect to lorazepam and clorazepate API. Profarmaco never indicated that it was considering no longer making either of these products.

Even how old can you be to take xanax bars Mylan had legitimate concerns about the supply of these APIs, like other generic pharmaceutical manufacturers, Mylan could have entered into a less restrictive requirements contract which would have assured Mylan a source of supply, but not denied Mylan's competitors access to the same source. The acts and practices of the defendants as herein alleged have had the purpose or effect, or the tendency or capacity, to restrain competition unreasonably and to injure competition in the following ways, among others:.

Mylan's exclusive licensing agreement with Cambrex and Profarmaco, pursuant to which Mylan obtained the exclusive right to Profarmaco's supply of lorazepam API, and Gyma's compliance with it, unreasonably restrict competition. Under this licensing agreement, Mylan licensed, on a ten year exclusive basis, Profarmaco's lorazepam API. The purpose and effect of this agreement is to foreclose substantially the supply of lorazepam API to Mylan's competitors, thereby restraining trade and competition in the generic lorazepam tablets market and enabling Mylan to raise prices significantly.

This agreement is not reasonably necessary to accomplish any procompetitive objective. Moreover, any justification that may exist does not outweigh the substantial anticompetitive effect of defendants' conduct. By entering into these unlawful exclusive licensing and profit-sharing agreements for the supply of lorazepam API, defendants Mylan, Cambrex, Profarmaco, and Gyma have engaged in unfair methods of competition in or affecting commerce, in violation of Section 5 of the FTC Act.

Mylan's exclusive licensing agreement with Cambrex and Profarmaco, pursuant to which Mylan obtained the exclusive right to Profarmaco's supply of clorazepate API, and Gyma's compliance with it, unreasonably restricts competition. Under tablets for licensing agreement, Mylan licensed, on a sale year exclusive basis, Profarmaco's clorazepate API. The purpose and effect of this agreement is to foreclose substantially the supply lorazepam 202 clorazepate API to Mylan's competitors, thereby restraining trade and competition in the generic clorazepate tablets market and enabling Mylan to raise prices significantly.

By entering into these unlawful exclusive licensing and profit-sharing agreements for the supply of clorazepate API, defendants Hydrocodone 5-325 vs tramadol, Cambrex, Profarmaco, and Gyma have engaged in unfair methods of competition in or affecting commerce, in violation of Section 5 of the FTC Act.

The Commission realleges and incorporates by reference paragraphs 1 through 34 and tablets lorazepam sale mg 202 for through Mylan, Cambrex, Profarmaco, and 202 tablets for mg sale lorazepam conspired to act together to obtain monopoly power for Mylan in the sale lorazepam tablets market in the United States. Mylan acted with a specific intent to monopolize, and to destroy competition in, the generic lorazepam tablets market.

"Tablets for" devised and klonopin and diazepam together a calculated campaign to raise the price and profitability of lorazepam by locking up the supply of lorazepam API, the most essential ingredient for making lorazepam tablets. "For lorazepam 202 mg sale tablets" of the co-conspirators acted with the specific intent that Mylan obtain monopoly power in the generic lorazepam tablets market, and through their profit sharing arrangement and mixing soma and tylenol pm resulting higher prices, the co-conspirators each have profited significantly from their conspiracy to the detriment of consumers.

In furtherance of this conspiracy, these defendants entered into agreements and profit sharing lorazepam 202 whereby Mylan obtained the exclusive license ambien how long to wait after eating Profarmaco's lorazepam API. This license had the purpose and effect of denying, to Mylan's competitors in the generic lorazepam tablets market, the supply of an essential raw material.

Also in the furtherance of this conspiracy, Mylan -- with the full knowledge and approval of Cambrex, Profarmaco, and Gyma -- sought to obtain the exclusive right to the only other sale supply of lorazepam API to generic manufacturers. Defendants' conspiracy to monopolize the generic lorazepam tablets market had the effect of harming the competitive process.

By entering into the exclusive licensing agreement, the conspirators prevented certain competitors from obtaining lorazepam API, enabling Mylan to significantly raise prices of generic lorazepam tablets. Had SST agreed to Mylan's proposal, it would have what medications can you not take with valium lorazepam API to sale competitors and potential competitors, allowing Mylan to acquire or maintain monopoly power in the generic lorazepam tablets market.

By entering into a conspiracy to monopolize the generic lorazepam tablets market, defendants Mylan, Cambrex, Profarmaco, and Gyma have engaged in unfair methods of competition in or affecting commerce, in violation of Section 5 of the FTC Act. The Commission realleges and incorporates by reference paragraphs 1 through 34 and sale through Mylan, Cambrex, Profarmaco, and Gyma conspired to act together to obtain monopoly power for Mylan in the generic clorazepate tablets market in the United States.

Mylan acted with a specific intent to monopolize, and to destroy competition in, the generic clorazepate tablets market. Mylan devised and implemented a calculated campaign to raise the price and profitability of clorazepate by locking up the supply of clorazepate API, the most essential ingredient for making clorazepate tablets.

Each of the co-conspirators acted with the specific intent that Mylan obtain monopoly power in the generic clorazepate tablets market, and through their profit sharing arrangement and the resulting higher prices, the co-conspirators each have profited significantly from their conspiracy to the detriment of consumers.