Channel MedSystems, Inc. v. Boston Scientific Corp.

CourtCourt of Chancery of Delaware
DecidedDecember 18, 2019
DocketC.A. No. 2018-0673-AGB
StatusPublished

This text of Channel MedSystems, Inc. v. Boston Scientific Corp. (Channel MedSystems, Inc. v. Boston Scientific Corp.) is published on Counsel Stack Legal Research, covering Court of Chancery of Delaware primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Channel MedSystems, Inc. v. Boston Scientific Corp., (Del. Ct. App. 2019).

Opinion

IN THE COURT OF CHANCERY OF THE STATE OF DELAWARE

CHANNEL MEDSYSTEMS, INC., ) a Delaware corporation, ) ) Plaintiff and ) Counterclaim Defendant, ) ) v. ) C.A. No. 2018-0673-AGB ) BOSTON SCIENTIFIC CORPORATION, ) a Delaware corporation, and NXT ) MERGER CORP., a Delaware corporation, ) ) Defendants and ) Counterclaim Plaintiffs. )

MEMORANDUM OPINION

Date Submitted: September 6, 2019 Date Decided: December 18, 2019

Daniel A. Mason, PAUL, WEISS, RIFKIND, WHARTON & GARRISON LLP, Wilmington, Delaware; William M. Lafferty, Thomas W. Briggs, Jr., and Richard Li, MORRIS, NICHOLS, ARSHT & TUNNELL LLP, Wilmington, Delaware; Andrew G. Gordon, Jaren Janghorbani, Paul A. Paterson, and Andrew J. Markquart, PAUL, WEISS, RIFKIND, WHARTON & GARRISON LLP, New York, New York; Attorneys for Plaintiff Channel Medsystems, Inc.

Karen L. Pascale, James M. Yoch, Jr., and Paul J. Loughman, YOUNG CONAWAY STARGATT & TAYLOR LLP, Wilmington, Delaware; Matthew M. Wolf, Edward Han, Amy DeWitt, Tara Williamson, William Louden, and William Young, Jr., ARNOLD & PORTER KAYE SCHOLER LLP, Washington, DC; Attorneys for Defendants Boston Scientific Corporation and NXT Merger Corp.

BOUCHARD, C. This post-trial opinion resolves claims arising from Boston Scientific

Corporation’s decision to terminate a merger agreement it entered into on November

1, 2017 (the “Agreement”) to acquire Channel Medsystems, Inc., an early stage

medical device company with one product—a global endometrial ablation device

named Cerene. Under the Agreement, Boston Scientific could only be required to

close the transaction if Cerene received FDA approval by September 30, 2019.

In late December 2017, Channel discovered that its Vice President of Quality,

Dinesh Shankar, had falsified expense reports and other documents as part of a

fraudulent scheme by which he stole approximately $2.6 million from the company.

Unbeknownst to Channel, some of the documents Shankar falsified were contained

in Channel’s submissions to the FDA seeking approval of the Cerene device.

Promptly after discovering Shankar’s fraud, Channel notified Boston

Scientific and the FDA. Channel interacted with both of them in a fully transparent

manner over the next few months as it thoroughly investigated and took actions to

remediate the effects of Shankar’s fraud. On April 18, 2018, the FDA accepted

Channel’s remediation plan, which strongly signaled that Shankar’s fraud would not

be the cause of any failure of the FDA to approve the Cerene device and which made

the FDA’s approval a distinct possibility. Despite this positive development, Boston

Scientific terminated the Agreement on May 11, 2018.

1 On March 28, 2019, consistent with the timeframe for receiving FDA

approval the parties expected when they entered into the Agreement, the FDA

approved the Cerene device. Trial of this action commenced the next month.

The primary issue in this case is whether Boston Scientific was entitled to

terminate the Agreement because (i) certain representations in the Agreement were

inaccurate as of the date it entered into the Agreement and (ii) the failure of such

representations to be true and correct has or reasonably would be expected to have a

“Material Adverse Effect” on Channel. For the reasons discussed below, the court

finds that although Shankar’s fraud caused a number of representations to be

inaccurate as of the date of the Agreement, Boston Scientific failed to prove that the

failure of such representations to be true and accurate reasonably would be expected

to have a Material Adverse Effect. The court thus concludes that Boston Scientific

was not entitled to terminate the Agreement and that Channel is entitled to an order

of specific performance requiring Boston Scientific to close the merger.

This decision reaches two other conclusions of note: first, that Boston

Scientific breached its obligation under the Agreement to use commercially

reasonable efforts to consummate the merger and, second, that Boston Scientific was

not fraudulently induced to invest approximately $11 million in Channel in making

a series of investments from 2015 to 2017.

2 I. BACKGROUND

The facts recited in this opinion are the court’s findings based on the testimony

and documentary evidence presented during a four-day trial held in April 2019. The

record includes stipulations of fact in the Pre-Trial Stipulation and Order, over 900

trial exhibits, twenty-five depositions, and live testimony from seven fact and five

expert witnesses.

A. The Parties

Plaintiff Channel MedSystems (“Channel” or the “Company”) is a Delaware

corporation headquartered in Emeryville, California.1 It is a privately held medical

technology company and the developer of the Cerene device.2

Defendant Boston Scientific Corporation (“Boston Scientific” or “BSC”) is a

Delaware corporation headquartered in Marlborough, Massachusetts.3 It is a

publicly traded medical technology company.4 Defendant NXT Merger Corp., a

wholly owned subsidiary of Boston Scientific, also is a Delaware corporation

headquartered in Marlborough, Massachusetts.5

1 Pre-Trial Stipulation and Order (“PTO”) ¶ II.B.1 (Dkt. 170). 2 Id. 3 Id. ¶ II.B.2. 4 Id. 5 Id. ¶ II.B.3. 3 B. Channel Develops the Cerene Device

In 2011, Channel began to develop Cerene, a device used for global

endometrial ablation, which is a procedure to treat heavy menstrual bleeding by

ablating the uterine lining. Most technologies for this procedure require general

anesthesia and must be performed using large pieces of equipment in a hospital

operating room or ambulatory surgery center.6

The procedure using Cerene is less painful because it uses cryotherapy (cold

temperature) rather than heat-based (burning) techniques.7 Channel designed

Cerene for use in an office setting without general anesthesia. Because Cerene is a

handheld, disposable device, physicians do not need to invest capital to purchase

equipment in order to use the device.8

C. The FDA Approval Process

As Boston Scientific has acknowledged, the FDA “stringently regulates

medical devices by means of a comprehensive regulatory system” that is “designed

to ensure the safety and effectiveness of medical devices.”9 Under this system—

established through the Federal Food, Drug, and Cosmetic Act (“FDCA”) and the

6 JX 403.006. 7 Tr. 6-7 (Coté). All citations to “Tr.” refer to the Trial Transcript Volumes I-IV from April 15-18, 2019 (Dkt. 186; Dkt. 187; Dkt. 188; Dkt. 189). 8 JX 180.006; Tr. 7 (Coté). 9 JX 21.020.

4 1976 Medical Device Amendments, 21 U.S.C. §§ 360c-360k—the FDA is charged

with “regulating the safety and effectiveness of medical devices, and the conditions

for their design, manufacture, performance, labeling, and use.”10

The FDCA divides medical devices into three classes—Class I, II, and III.11

Class III devices, such as Cerene, “are subject to the most stringent regulatory

controls of all device classes.”12 According to Boston Scientific, these devices must

undergo an “indisputably thorough, rigorous, and costly pre-market review (some

1,200 FDA man hours at hundreds of thousands of dollars in cost) by the FDA.”13

Before a company can market a Class III device, the FDA must review and

provide a premarket approval (“PMA”) of the device. In order to conduct a clinical

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Channel MedSystems, Inc. v. Boston Scientific Corp., Counsel Stack Legal Research, https://law.counselstack.com/opinion/channel-medsystems-inc-v-boston-scientific-corp-delch-2019.