CURIA IP HOLDINGS, LLC v. SALIX PHARMACEUTICALS, LTD.

CourtDistrict Court, D. New Jersey
DecidedAugust 17, 2022
Docket2:21-cv-19293
StatusUnknown

This text of CURIA IP HOLDINGS, LLC v. SALIX PHARMACEUTICALS, LTD. (CURIA IP HOLDINGS, LLC v. SALIX PHARMACEUTICALS, LTD.) 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
CURIA IP HOLDINGS, LLC v. SALIX PHARMACEUTICALS, LTD., (D.N.J. 2022).

Opinion

Note for Publication

UNITED STATES DISTRICT COURT DISTRICT OF NEW JERSEY

CURIA IP HOLDINGS, LLC,

Plaintiff,

Civil Action No. 21-19293 (ES) (JRA) v. OPINION SALIX PHARMACEUTICALS, LTD.; SALIX PHARMACEUTICALS, INC.; BAUSCH HEALTH COMPANIES INC.; ALFASIGMA S.P.A.; and ALFASIGMA USA, INC.,

Defendants.

SALAS, DISTRICT JUDGE Before the Court is Defendants Salix Pharmaceuticals, Ltd., Salix Pharmaceuticals, Inc., Bausch Health Companies, Inc., Alfasigma S.P.A., and Alfasigma USA, Inc.’s motion to dismiss Plaintiff Curia IP Holdings, LLC’s Complaint pursuant to Federal Rule of Civil Procedure 12(b)(6). (D.E. No. 33). The Court has considered the parties’ submission and decides this matter without oral argument. See Fed. R. Civ. P. 78(b); L. Civ. R. 78.1(b). For the following reasons, Defendants’ motion is GRANTED. I. BACKGROUND Plaintiff is the current owner and assignee of U.S. Patent Nos. 9,186,355 (the “’355 patent”), 10,556,915 (the “’915 patent”), 10,745,415 (the “’415 patent”), and 10,961,257 (the “’257 patent”). (D.E. No. 1 (“Compl.”) ¶¶ 50–52). Plaintiff alleges that it filed the ‘355 patent application on July 26, 2013, and filed the ‘915 patent, the ‘415 patent, and the ‘257 patent applications on March 31, 2014. (Id. ¶¶ 49–52). Each patent contains claims directed to mixtures containing certain ratios of the α and β polymorphic forms of rifaximin. (Id. ¶ 53). Defendants are manufacturers of pharmaceutical products. (Id. ¶¶ 32–42). According to Plaintiff, Defendants’ product XIFAXAN® is a prescription antibiotic containing rifaximin. (Id. ¶ 35). Plaintiff alleges that Defendants have been selling a 200 mg dose of XIFAXAN® since July 2004 and a 550 mg dose of XIFAXAN® since May 2010. (Id.).

On October 25, 2021, Plaintiff filed suit against Defendants. Plaintiff claims that Defendants’ sale of XIFAXAN®, specifically for those sold after November 2015, infringe the four patents referenced above. (Id. ¶¶ 59–94). Plaintiff also alleges that Defendants’ infringement is willful, and it seeks damages and other relief. (Id. ¶ 95). Defendants move to dismiss the Complaint, arguing that the Plaintiff’s allegations confirm that XIFAXAN® was on sale prior to their patent applications and therefore constitutes prior art. (D.E. No. 33; see also D.E. No. 33-1 (“Mov. Br.”) at 1–2; D.E. No. 44 (“Reply”)). II. LEGAL STANDARD

In assessing whether a complaint states a cause of action sufficient to survive dismissal under Federal Rule of Civil Procedure 12(b)(6), the Court accepts “all well-pleaded allegations as true and draw[s] all reasonable inferences in favor of the plaintiff.” City of Cambridge Ret. Sys. v. Altisource Asset Mgmt. Corp., 908 F.3d 872, 878 (3d Cir. 2018). “[T]hreadbare recitals of the elements of a cause of action, legal conclusions, and conclusory statements” are all disregarded. Id. at 878–79 (quoting James v. City of Wilkes-Barre, 700 F.3d 675, 681 (3d Cir. 2012)). The complaint must “contain sufficient factual matter, accepted as true, to state a claim to relief that is plausible on its face,” and a claim is facially plausible when the plaintiff “pleads factual content that allows the court to draw the reasonable inference that the defendant is liable for the misconduct alleged.” Zuber v. Boscov’s, 871 F.3d 255, 258 (3d Cir. 2017) (first quoting Santiago v. Warminster Twp., 629 F.3d 121, 128 (3d Cir. 2010); and then quoting Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009)). III. DISCUSSION As noted, Defendants argue that Plaintiff’s Complaint, as pled, admits that XIFAXAN®

was manufactured and sold prior to the date of the first filed patent application. (Mov. Br. at 5). In light of that admission, Defendants argue that their product is necessarily prior art and therefore invalidates Plaintiff’s four patents. (Id. at 6). The Court agrees. Under 35 U.S.C. § 102(a)(1), a person may not obtain a patent if the claimed invention was “on sale[] or otherwise available to the public before the effective filing date of the claimed invention” (emphasis added).1 An invention that was on sale before the filing date of the patent application is “prior art.” To trigger this on-sale bar, the defendant bears the burden of satisfying two conditions, both of which must be satisfied prior to the filing date of the patents—that is, the “critical date.” Vanmoor v. Wal-Mart Stores, Inc., 201 F.3d 1363, 1366 (Fed. Cir. 2000) (citing Pfaff v. Wells Elecs., 525 U.S. 55, 67 (1998)). First, the defendant’s invention must be the subject

of a commercial offer for sale, and second, the invention must be ready for patenting. Id. The second condition may be satisfied in at least two ways: “by proof of reduction to practice before the critical date; or by prior to the critical date the invention had prepared drawings or other descriptions of the invention that were sufficiently specific to enable a person skilled in the art to practice the invention.” Pfaff, 525 U.S. at 66–67. Section 102(a)(1) reflects the old maxim of patent law, “that which infringes, if later, anticipates, if earlier.” Peters v. Active Mfg. Co., 129 U.S. 530, 537 (1889). Courts have found that a defendant satisfies its burden under the on-sale bar based solely

1 Section 102(b) contains exceptions that neither appear to be applicable here nor have been argued by either party. on the plaintiff’s own admissions. See Vanmoor, 201 F.3d at 1366; Evans Cooling Sys. v. GMC, 125 F.3d 1488 (Fed. Cir. 1997). For example, in Vanmoor, the Federal Circuit held that the plaintiff’s patent was invalid because the accused product was placed on sale prior to the critical date. 201 F.3d at 1366. In Evans Cooling, the Federal Circuit determined that the presence of a

sales offer for the accused product prior to the critical date invalidated the plaintiff’s patent for the product. 125 F.3d at 1452. Although Vanmoor and Evans Cooling arose on motions for summary judgment, both courts found that the patent challenger met its burden of proving invalidity by clear and convincing evidence based solely on the patentee’s allegation that the accused product infringed its patent and was on sale prior to the critical date. Vanmoor, 201 F.3d at 1366; Evans Cooling, 125 F.3d at 1451.2 However, an accused infringer meets its burden only if it “clearly practic[es] only that which was in the prior art, and nothing more.” Tate Access Floors v. Interface Architectural Res., Inc., 279 F.3d 1357, 1367 (Fed. Cir. 2002). In Tate, the Federal Circuit rejected the argument that prior art existed through textbook teachings on beveling, or sloping, the edges of laminate. Id. at

1362–63.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Peters v. Active Manufacturing Co.
129 U.S. 530 (Supreme Court, 1889)
Pfaff v. Wells Electronics, Inc.
525 U.S. 55 (Supreme Court, 1998)
Ashcroft v. Iqbal
556 U.S. 662 (Supreme Court, 2009)
Santiago v. Warminster Township
629 F.3d 121 (Third Circuit, 2010)
Ferag Ag v. Quipp Incorporated
45 F.3d 1562 (Federal Circuit, 1995)
Cheryl James v. Wilkes Barre City
700 F.3d 675 (Third Circuit, 2012)
Craig Zuber v. Boscovs
871 F.3d 255 (Third Circuit, 2017)
Vanmoor v. Wal-Mart Stores, Inc.
201 F.3d 1363 (Federal Circuit, 2000)

Cite This Page — Counsel Stack

Bluebook (online)
CURIA IP HOLDINGS, LLC v. SALIX PHARMACEUTICALS, LTD., Counsel Stack Legal Research, https://law.counselstack.com/opinion/curia-ip-holdings-llc-v-salix-pharmaceuticals-ltd-njd-2022.