Biogen Inc. v. Sandoz Inc.

CourtDistrict Court, D. Delaware
DecidedMarch 10, 2025
Docket1:22-cv-01190
StatusUnknown

This text of Biogen Inc. v. Sandoz Inc. (Biogen Inc. v. Sandoz Inc.) is published on Counsel Stack Legal Research, covering District Court, D. Delaware primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

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

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).

[c]ourt applies the same standard of legal sufficiency as [it] applies under Rule 12(b)(6).” Jd. (quotation marks omitted). “Ifa motion to amend . . . is filed after the deadline set for amendments under a scheduling order, the moving party must also satisfy Rule 16(b)(4) of the Federal Rules of Civil Procedure.” W. R. Grace & Co.-Conn. v. Elysium Health, Inc., No. CV 20-1098-GBW, 2023 WL 6200280, at *4 (D. Del. Sept. 22, 2023); see Truinject Corp v. Galderma S.A., No. CV 19-00592-GBW, 2023 WL 5993170, at *1 (D. Del. Sept. 15, 2023). “The Rule 16(b)(4) standard does not allow ‘an inability to timely amend a pleading within the scheduling order deadline [to] excuse[ | a party from exercising diligence in seeking leave to amend outside of the deadline.’” Allergan USA, Inc. v. MSN Lab’ys Priv. Ltd., No. CV 19-1727-RGA, 2022 WL 11761898, at *3 (D. Del. Oct. 20, 2022) (alterations in original) (quoting NRT Tech. Corp. v. Everi Holdings Inc., No. CV 19-804- MN-SRF, 2022 WL 354291 (D. Del. Jan. 11, 2022)). “Ifa movant meets its burden under Rule 16(b)(4) to show that good cause exists, the court may then consider whether it should grant leave to amend under Rule 15(a)(2).” iCeutica Pty Ltd v. Novitium Pharma LLC, No.

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Bluebook (online)
Biogen Inc. v. Sandoz Inc., Counsel Stack Legal Research, https://law.counselstack.com/opinion/biogen-inc-v-sandoz-inc-ded-2025.