Biogen Inc. v. Sandoz Inc.

District Court, D. Delaware·Decided March 10, 2025·No. 1:22-cv-01190·Unknown

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE BIOGEN INC. and BIOGEN MA INC., Plaintiffs, v. C.A. No. 22-1190-GBW SANDOZ INC. and POLPHARMA BIOLOGICS S.A., Defendants.

MEMORANDUM ORDER Plaintiffs Biogen Inc. and Biogen MA Ince. (collectively, “Biogen” or “Plaintiffs”) filed their Second Amended Complaint (D.I. 98) (the “Operative Complaint”) against Defendants Sandoz Inc. (“Sandoz”) and Polpharma Biologics S.A. (“Polpharma’’) (collectively, “Defendants”) to “halt Sandoz’s and Polpharma’s [(purported)] past, current, and future intended infringement of Biogen’s rights pursuant to the patent laws of the United States.” D.I. 98 4] 2; see Biogen Inc. v. Sandoz Inc., No. CV 22-1190-GBW, 2023 WL 7130655, at *1-2 (D. Del. June 29, 2023). Sandoz filed its “Answer and Affirmative Defenses to the Second Amended Complaint” (“Sandoz’s Operative Answer”), in which it raised “Patent Exhaustion” and “License” as affirmative defenses. D.I. 153 at 1 (first quote), 57 (second quote and third quote), Polpharma filed its “Answer and Affirmative Defenses to the Second Amended Complaint”, in which it raised “Patent Exhaustion” and “License” as affirmative defenses. D.I. 314 at 1 (first quote), 58 (second quote), 59 (third quote). Pending before the Court is Defendant Sandoz Inc.’s Motion to Re-Designate Its Affirmative Defenses of License and Patent Exhaustion as Counterclaims, or in the Alternative,

for Leave to Amend Sandoz Inc.’s Answer, Affirmative Defenses, and Amended Counterclaims to Second Amended Complaint (D.I. 518) (“Sandoz’s Motion”), which has been fully briefed (D.I. 519; D.I. 529; D.I. 530). For the following reasons, the Court denies Sandoz’s Motion. Since the Court was able to resolve Sandoz’s Motion without oral argument, the Court also denies-as- moot the parties’ request for a teleconference (D.I. 533). IL BACKGROUND Sandoz “move[d] .. ., pursuant to Federal Rules of Civil Procedure 8(c)(2), 15(a)(2), and 16(b)(4), and District of Delaware Local Rule 15.1,” to “re-designate its affirmative defenses of license and patent exhaustion as counterclaims, or in the alternative, for leave to amend its Answer, Affirmative Defenses and Amended Counterclaims to Second Amended Complaint.” D.I. 518 atl; see DI. 519 at 1-2 (Sandoz... is seeking to redesignate its affirmative defenses as counterclaims for declaratory relief. . . . In the alternative, Sandoz moves to amend its counterclaims to add declaratory judgment causes of action for license, exhaustion, and estoppel.”); see also D.I. 518-3 (Sandoz’s proposed re-designated Answer, Affirmative Defenses and Amended Counterclaims to Second Amended Complaint). Sandoz contends that its primary request “to redesignate its affirmative defenses as counterclaims for declaratory relief... . is squarely within Rule 8(c)(2).” D.I. 519 at 1 (citing Rocheux Int’l of N.J., Inc. v. U.S. Merchants Fin. Grp., Inc., 741 F. Supp. 2d 651 (D.N.J. 2010)). Sandoz contends that its alternative request “to amend its counterclaims to add declaratory judgment causes of action for license, exhaustion, and estoppel” is supported by “good cause.” D.I. 519 at 2.

IL. LEGAL STANDARDS A. Rule 8(c)(2) of the Federal Rules of Civil Procedure “Pursuant to the Federal Rules of Civil Procedure, civil actions are initiated by a complaint and the responsive pleading is an answer, counterclaim, or motion to dismiss.” Jonathan H. v. The Souderton Area Sch. Dist., 562 F.3d 527, 529 (3d Cir. 2009). Federal Rule of Civil Procedure “Rule 13 [] provides that crossclaims and counterclaims must proceed via pleadings[.]” CPR Memt., S.A. v. Devon Park Bioventures, L.P., 19 F.4th 236, 243 (3d Cir. 2021). Pursuant to Federal Rule of Civil Procedure 8(c)(2), “[i]f a party mistakenly designates a defense as a counterclaim, or a counterclaim as a defense, the court must, if justice requires, treat the pleading as though it were correctly designated, and may impose terms for doing so.” Fed. R. Civ. P. 8(c)(2); see Reiter v. Cooper, 507 U.S. 258, 263 (1993). “Rule 8(c)(2) generally favors defendants by construing responsive pleadings liberally to maximize the defendant’s available legal theories.” Roche, 583 F.3d at 840. B. Rule 15(a)(2) of the Federal Rules of Civil ProcedureFederal Rule of Civil Procedure 15(a)(2) provides that a district court should ‘freely give leave [to amend] when justice so requires.’” Talley v. Wetzel, 15 F.4th 275, 286 n.6 (3d Cir. 2021) (alterations in original). “Despite this liberal standard, leave to amend may be denied when there is undue delay, bad faith, dilatory motive, prejudice, [or] futility.” Jd. (quotation marks omitted); see LaSpina v. SEIU Pa. State Council, 985 F.3d 278, 291 (3d Cir. 2021). “Amendment would be futile when the complaint, as amended, would fail to state a claim upon which relief could be granted.” 15 F.4th at 286 n.6 (quotation marks omitted). “When assessing futility, the [district

' In this context, “[t]he phrase ‘if justice requires’ is not well defined.” Bd. of Trustees of Leland Stanford Junior Univ. v. Roche Molecular Sys., Inc., 583 F.3d 832, 840 (Fed. Cir. 2009), aff’d, 563 U.S. 776 (2011).

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Biogen Inc. v. Sandoz Inc., (D. Del. 2025).

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