DMK Pharmaceuticals Corp. v. Catalent Belgium, S.A.

CourtUnited States Bankruptcy Court, D. Delaware
DecidedAugust 14, 2025
Docket24-50070
StatusUnknown

This text of DMK Pharmaceuticals Corp. v. Catalent Belgium, S.A. (DMK Pharmaceuticals Corp. v. Catalent Belgium, S.A.) is published on Counsel Stack Legal Research, covering United States Bankruptcy Court, D. Delaware primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
DMK Pharmaceuticals Corp. v. Catalent Belgium, S.A., (Del. 2025).

Opinion

IN THE UNITED STATES BANKRUPTCY COURT FOR THE DISTRICT OF DELAWARE In re: ) Ch. 11 ) DMK PHARMACEUTICALS CORP et al., ) ) Case No. 24-10153 (MFW) Debtors. ) ) (Jointly Administered) ) ) DMK PHARMACEUTICALS CORP. and ) Adv. No. 24-50070 (MFW) ADAMIS PHARMACEUTICALS CORP. ) ) Plaintiffs, ) ) v. ) ) CATALENT BELGIUM, S.A. and ) Re: Adv. D.I. 1, 28, CATALENT PHARMA SOLUTIONS, INC. ) 29, 39, 40, 45, 48 ) Defendants. ) MEMORANDUM OPINION1 Before the Court is the Motion of Catalent Belgium, S.A. and Catalent Pharma Solutions, Inc. (collectively, the “Defendants”) to Compel Arbitration and to Dismiss the Complaint and the Motion of DMK Pharmaceuticals Corporation (“DMK”) as futile and Adamis Pharmaceuticals Corporation (“Adamis”) (collectively, the “Plaintiffs”) for Leave to Amend their Complaint.2 For the reasons stated below, the Court will grant in part and deny in 1 The Court is not required to state findings of fact or conclusions of law pursuant to Rule 7052 of the Federal Rules of Bankruptcy Procedure. Instead, the facts recited are those well- pled allegations in the Complaint which must be accepted as true for the purposes of this Motion to Dismiss. Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009). 2 Adv. D.I. 28 & 39. References to the docket in the adversary proceeding are to “Adv. D.I.#,” while references to the docket in the main bankruptcy case are to “D.I. #.” part the Motion to Compel Arbitration and to Dismiss and will grant in part and deny in part the Motion to Amend.

I. FACTUAL AND PROCEDURAL BACKGROUND DMK and its affiliated subsidiaries (collectively, the “Debtors”) were a family of clinical stage neuro-biotechnology pharmaceutical companies that own various drug therapies.3 One of the Debtors’ products, SYMJEPI, was an injectable epinephrine product approved by the FDA for the emergency treatment of allergic reactions (Type 1) including anaphylaxis.4 On August 13, 2015, a predecessor to DMK5 entered into a supply agreement with Catalent Belgium S.A. (“Catalent Belgium”) for a five-year term, automatically extended for two successive two-year terms (the “Supply Agreement”).6 On May 18, 2020, the same entity entered into a quality agreement with Catalent Pharma Solutions, Inc. (“Catalent Pharma”) for the manufacture, release testing, and stability testing of SYMJEPI (the “Quality Agreement”).7 All formulations of SYMJEPI and filling processes

3 D.I. 4 ¶ 9. 4 Id. ¶ 16. 5 The signatory to the Supply Agreement was Adamis, which was subsequently merged into Aardvark Merger Sub, Inc., which changed its name to DMK. Adv. D.I. 1 ¶¶ 9-10, 19. 6 Id. ¶ 19. 7 Id. ¶ 20. 2 were validated before Catalent Pharma began manufacturing.8 On February 2, 2024, the Debtors filed petitions for reorganization under chapter 11 of the Bankruptcy Code. On October 28, 2024, the Court confirmed the Debtors’ First Amended Joint Chapter 11 Plan of Liquidation.9 The Plan vested all the assets of the estate in RK Consultants, LLC, as the Liquidation Trustee.10 The Debtors scheduled the Defendants as having a contingent, unliquidated, and disputed claim of approximately $1.8 million;11 Catalent Belgium filed a proof of claim in the amount of approximately 1.5 million Euros on May 17, 2024, which was beyond the claims bar date of April 24, 2024.12 On May 30, 2024, the Plaintiffs filed a complaint against the Defendants for breach of contract, objection to their claim, and equitable subordination of that claim (the “Complaint”).13 On February 2, 2025, the Defendants filed a Motion to Compel Arbitration and Dismiss the Complaint.14 On April 9, 2025, the

8 Id. ¶ 24. 9 D.I. 523. 10 Id. ¶¶ 13, 50; D.I. 528 ¶ 2. 11 Id. ¶ 18. 12 Id. ¶¶ 3, 53-54. 13 Id. ¶ 1. 14 Adv. D.I. 28-29. 3 Plaintiffs filed a Motion for Leave to Amend the Complaint, inter alia, to add counts for fraudulent inducement and gross negligence.15 In response, the Defendants asserted that the Motion to Amend was untimely and futile because the new claims asserted by the Plaintiffs are also subject to arbitration.16 The Plaintiffs filed a Reply disputing those contentions.17 The Motions have now been fully briefed and are ripe for decision.18

II. JURISDICTION The Bankruptcy Court has jurisdiction over all “proceedings arising under title 11 or arising in or related to a case under title 11.”19 The filing of a proof of claim by a creditor subjects that creditor to the Bankruptcy Court’s jurisdiction to adjudicate that claim and claims by the debtor against the creditor which are so interrelated to that claim as to be part of the claims adjudication process.20 The Court finds that the

15 Adv. D.I. 39-40. 16 Adv. D.I. 45. 17 Adv. D.I. 48. 18 Adv. D.I. 1 ¶¶ 29, 40, 48. 19 28 U.S.C. § 157(b)(1). 20 Langenkamp v. Culp, 498 U.S. 42, 44-45 (1990) (holding that a creditor who files a proof of claim subjects itself to the equitable jurisdiction of the bankruptcy court to adjudicate that claim and forfeits its right to a jury trial on a preference action which is related to the claim allowance process). 4 claims in the Plaintiffs’ Complaint are core claims subject to the Court’s jurisdiction because they involve an objection toa claim filed against the estate and counterclaims by the Plaintiffs, both of which are based on the parties’ Agreements.’! Although Catalent does not consent to the entry of a final order or judgment by the Court if it is determined that the Court cannot enter a final order or judgment consistent with Article III of the United States Constitution,* it is not necessary for the Court to decide that issue at this time. Even if the Court does not have constitutional authority to enter a final order, the Court does have authority to enter orders on preliminary matters to the extent they do not constitute a final adjudication.*? That includes specifically the authority of the

at 28 U.S.C. § □□□ □□□ (2) (B) & (C), § 1334. 22 Adv. D.1I. 3. See Stern v. Marshall, 564 U.S. 462, 503 (2011) (holding that while the bankruptcy court had statutory authority to enter final judgment on core counterclaim, it lacked constitutional authority to do so); Wellness Int’l Network, Ltd. v. Sharif, 575 U.S. 665, 683-84 (2015) (holding that the bankruptcy court may enter a final order without offending Article III so long as the parties consent, expressly or impliedly). 28 See O’Toole v. McTaggart (In re Trinsum Grp., Inc.), 467 B.R. 734, 738 (Bankr. S.D.N.Y. 2012) (holding that “both before and after Stern v. Marshall, it is clear that the bankruptcy court may handle all pretrial proceedings, including the entry of an interlocutory order dismissing fewer than all of the claims in an adversary complaint.”) (citations omitted). See also Am, Media Inc. v. Anderson Mgmt. Servs. (In re Anderson News, LLC), Civ. No. 15-mc-199-LPS, 2015 WL 4966236, at *1-2 (D. Del. Aug. 19, 2015) (holding that bankruptcy court’s authority to enter final orders on non-core claims was not implicated where the

Court to determine whether the Complaint states a plausible claim on which relief can be granted.24

III. STANDARD OF REVIEW A. Rule 12(b)(6)25 Rule 12(b)(6) provides for dismissal for “failure to state a claim upon which relief can be granted.”26 Under Rule 12(b)(6), a complaint “does not need detailed factual allegations, [but] a plaintiff’s obligation to provide the ‘grounds’ of his ‘entitle[ment] to relief’ requires more than labels and conclusions, and a formulaic recitation of the elements of a cause of action will not do.”27

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DMK Pharmaceuticals Corp. v. Catalent Belgium, S.A., Counsel Stack Legal Research, https://law.counselstack.com/opinion/dmk-pharmaceuticals-corp-v-catalent-belgium-sa-deb-2025.