Cathy Hartney, Jennifer Romolo, Kristin Johnson, Ashley Levernez, Debra Flaska, Pratibha Prince, Ashleigh Bohlman, and Vincenta Wolfe, on behalf of themselves and all others similarly situated v. Zoetis, Inc.

CourtDistrict Court, D. New Jersey
DecidedOctober 15, 2025
Docket2:24-cv-09698
StatusUnknown

This text of Cathy Hartney, Jennifer Romolo, Kristin Johnson, Ashley Levernez, Debra Flaska, Pratibha Prince, Ashleigh Bohlman, and Vincenta Wolfe, on behalf of themselves and all others similarly situated v. Zoetis, Inc. (Cathy Hartney, Jennifer Romolo, Kristin Johnson, Ashley Levernez, Debra Flaska, Pratibha Prince, Ashleigh Bohlman, and Vincenta Wolfe, on behalf of themselves and all others similarly situated v. Zoetis, Inc.) is published on Counsel Stack Legal Research, covering District Court, D. New Jersey primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Cathy Hartney, Jennifer Romolo, Kristin Johnson, Ashley Levernez, Debra Flaska, Pratibha Prince, Ashleigh Bohlman, and Vincenta Wolfe, on behalf of themselves and all others similarly situated v. Zoetis, Inc., (D.N.J. 2025).

Opinion

NOT FOR PUBLICATION

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF NEW JERSEY CATHY HARTNEY, JENNIFER ROMOLO, KRISTIN JOHNSON, ASHLEY LEVERNEZ, DEBRA FLASKA, Civil Action No. 24-9698 (SDW) (AME) PRATIBHA PRINCE, ASHLEIGH BOHLMAN, and VINCENTA WOLFE, on OPINION behalf of themselves and all others similarly situated, October 15, 2025 Plaintiffs, v. ZOETIS, INC., Defendant.

WIGENTON, District Judge.

Before this Court is Defendant Zoetis, Inc.’s (“Zoetis” or “Defendant”) Motion to Dismiss Plaintiffs’ Third Amended Class Action Complaint (D.E. 35 (the “TAC”)) pursuant to Federal Rule of Civil Procedure (“Rule”) 12(b)(6) and to strike class allegations. (D.E. 39 (“Motion”).) Jurisdiction is proper pursuant to 28 U.S.C. §§ 1332(d)(2)-(6) and 1367. Venue is proper pursuant to 28 U.S.C. § 1391(b). This Court considers this matter without oral argument pursuant to Federal Rule of Civil Procedure 78. For the reasons stated herein, Defendant’s Motion is GRANTED IN PART and DENIED IN PART, and the Third Amended Complaint is hereby DISMISSED WITHOUT PREJUDICE. I. BACKGROUND This putative class action arises from the administration of Librela, a monoclonal antibody marketed by Zoetis for the control of osteoarthritis‑related pain in dogs. Eight named Plaintiffs bring claims on behalf of themselves and a proposed nationwide class, alleging that Zoetis misrepresented Librela’s safety, failed to warn veterinarians and pet owners about severe adverse events, and breached various statutory and common‑law duties. The Plaintiffs’ causes of action include failure‑to‑warn, design defect, breach of express and implied warranties, consumer fraud

violations under several state statutes, fraud, negligent misrepresentation, and unjust enrichment. A. Factual History1 a. Librela and Reported Adverse Events Librela is a long‑acting monoclonal antibody (bedinvetmab) administered by monthly injection for the management of osteoarthritis in dogs. (TAC ¶¶ 1–2.) According to the TAC, thousands of adverse events have been reported following Librela injections, including neurological injuries such as ataxia, convulsions, and proprioception abnormalities; musculoskeletal injuries such as lameness, muscle tremors, and paresis; hepatic and pancreatic injuries characterized by elevated liver enzymes or pancreatitis; and death. (Id. ¶ 1.) There is no antidote for the drug once administered. (Id. ¶ 2.) Plaintiffs allege that Zoetis failed to inform consumers and veterinarians about these dangers and misrepresented Librela as being safe for dogs. (Id. ¶ 4.) The TAC asserts that the product’s warning label, as well as advertising and promotional materials, including

direct‑to‑consumer marketing, failed to warn that Librela could cause the adverse events described above. (Id.) Zoetis allegedly continued to tout Librela’s safety even after an FDA‑mandated label change in January 2025, which added certain warnings. (Id. ¶ 5.) Plaintiffs contend that further warnings regarding liver and pancreas risks may still be required. (Id.) Plaintiffs further allege

1 The facts set forth in this section are drawn from the Third Amended Complaint and are presumed true solely for purposes of this Motion. See Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009). that adequate warnings would have altered both veterinarians’ prescribing decisions and pet owners’ consent, and that Zoetis’s misrepresentations caused them to purchase Librela injections they otherwise would not have. (Id. ¶¶ 6–7.) The cumulative effect of these misrepresentations has allegedly resulted in millions of dollars in costs for pet owners, including the price of the

injections, veterinary expenses, and in some cases the loss of their dogs. (Id. ¶ 9.) b. Allegations of the Named Plaintiffs The TAC details the experiences of eight named plaintiffs from various states. (See generally id. ¶¶ 10–75.) Cathy Hartney, a resident of Florida, consented to a Librela injection for her dog Jake based on Zoetis’s representations that the drug was safe. Within days, Jake developed increased thirst, decreased appetite, limited mobility, and worsening pain; he ultimately had to be euthanized. Hartney alleges that she spent money on the injection and subsequent veterinary care and would not have consented to Librela had she known the risks. (Id. ¶¶ 10–17.) Jennifer Romolo, an Illinois resident, consented to a Librela injection for her dog Blue. She similarly alleges that Zoetis’s marketing led her to believe the drug was safe. After the

injection, Blue experienced decreased appetite, increased thirst, vomiting, lethargy, anemia, and a rash. Romolo contends that she incurred veterinary expenses and emotional distress and would not have chosen Librela if adequately warned. (Id. ¶¶ 18–25.) Kristin Johnson, a resident of Texas, administered Librela to her two golden retrievers, Dixie and Jack, over several months. She alleges that one dog developed deafness and bowel control issues and the other suffered ataxia, hind leg weakness, and growths. Despite treatment, Jack ultimately died. Johnson asserts that she paid for multiple injections, incurred veterinary costs, and endured emotional anguish. (Id. ¶¶ 26–35.) Ashley Levernez, another Texas resident, claims that her Australian shepherd Maisley developed inappetence, increased pain, muscle atrophy, ataxia, and eventually hind leg paralysis following Librela injections. She alleges that despite treatment, Maisley’s condition deteriorated, and she incurred significant medical expenses. (Id. ¶¶ 36–43.) The TAC contains analogous narratives for the remaining Plaintiffs — Debra Flaska of

California, Pratibha Prince of Missouri, Ashleigh Bohlmann of Virginia, and Vincenta Wolfe of New Jersey — all of whom allege that they relied on Zoetis’s representations, consented to Librela injections, and later witnessed their dogs suffer severe adverse events. (Id. ¶¶ 44–75.) Each Plaintiff contends that adequate warnings would have prevented their consent and that they incurred economic losses and emotional harm as a result. The TAC further alleges that Plaintiffs reported their dogs’ adverse events to Zoetis and the FDA and that Zoetis continued to market Librela as safe despite these reports. c. Marketing and Regulatory History Plaintiffs allege that veterinarians use a wide variety of products to maintain animal health and safety, and that the consumer market for pet medication is substantial. (Id. ¶ 88.) In 2021, the

global animal health market was valued at nearly $40 billion, with the United States accounting for about one-third of that figure, or roughly $13 billion. (Id. ¶ 89.) Plaintiffs allege that pet owners rely on these products to prevent and treat numerous illnesses, and their willingness to spend is heightened by the strength of the human–animal bond. Studies show that 95% of dog and cat owners view their pets as family members, and a majority report that they would pay whatever is necessary to secure veterinary care for them. (Id. ¶¶ 90–91.) In 2021 alone, Americans spent approximately $103 billion on their pets, with significant portions devoted to veterinary care and medications. (Id. ¶ 92.) Dogs, like humans, suffer from a range of diseases, including osteoarthritis, which is the most common canine joint disease. (Id. ¶¶ 93–94.) Librela is a monoclonal antibody therapy designed to block nerve growth factor (“NGF”), a protein associated with pain transmission. (Id.

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Cathy Hartney, Jennifer Romolo, Kristin Johnson, Ashley Levernez, Debra Flaska, Pratibha Prince, Ashleigh Bohlman, and Vincenta Wolfe, on behalf of themselves and all others similarly situated v. Zoetis, Inc., Counsel Stack Legal Research, https://law.counselstack.com/opinion/cathy-hartney-jennifer-romolo-kristin-johnson-ashley-levernez-debra-njd-2025.