DMK Pharmaceuticals Corp. v. USWM, LLC

CourtUnited States Bankruptcy Court, D. Delaware
DecidedApril 25, 2025
Docket24-50071
StatusUnknown

This text of DMK Pharmaceuticals Corp. v. USWM, LLC (DMK Pharmaceuticals Corp. v. USWM, LLC) 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. USWM, LLC, (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 et al., ) Adv. No. 24-50071 (MFW) ) Plaintiffs, ) ) v. ) ) USWM, LLC, ) Re: Adv. D.I. 1, 14, ) 15, 18, 21, 22 ) Defendant. ) MEMORANDUM OPINION Before the Court is the Motion of USWM, LLC (“USWM”) to Dismiss the Debtors’ Complaint.1 For the reasons stated below, the Court will deny the Motion. I. FACTUAL AND PROCEDURAL BACKGROUND2 DMK Pharmaceuticals Corp. and its affiliated subsidiaries (collectively the “Debtors”) are a family of clinical stage 1 Adv. D.I. 1. 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. #.” 2 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). neuro-biotechnology pharmaceutical companies that own various therapies focused on addressing the opioid epidemic.3 One of the Debtors’ products, ZIMHI, is an injectable naloxone antidote used to treat opioid overdoses.4 USWM is a pharmaceutical company that develops, licenses, and brings to market various healthcare products.5 Pre-petition, the Debtors had entered into a Distribution and Commercialization Agreement (the “Agreement”) with USWM to market and distribute ZIMHI.6 Under the Agreement, USWM contracted to serve as the exclusive distributor, marketer, and seller of ZIMHI for ten years.7 The Agreement contemplated that USWM would develop a commercialization plan for ZIMHI and use commercially reasonable efforts to execute that plan.8 The parties mutually agreed to terminate the Agreement on December 21, 2023.9

3 Adv. D.I. 4 ¶¶ 9, 14. 4 Adv. D.I. 1 ¶¶ 28-29. 5 Adv. D.I. 15 at 3. 6 Adv. D.I. 1 ¶ 1. 7 Id. ¶ 49. 8 Id. ¶¶ 50-51. 9 Id. ¶ 64. 2 On February 2, 2024, the Debtors filed petitions under chapter 11 of the Bankruptcy Code.10 On April 17, 2024, USWM filed a proof of claim against the Debtors in the amount of $9,040,615.37 for amounts allegedly due under the Agreement.11 On June 3, 2024, the Debtors filed a Complaint against USWM asserting claims for breach of the Agreement and seeking to disallow USWM’s proof of claim.12 On August 2, 2024, USWM filed a Motion to Dismiss the Complaint for failure to state a claim.13 The matter has been fully briefed14 and is ripe for decision.

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.”15 The filing of a proof of claim by a creditor

subjects that creditor to the Bankruptcy Court’s jurisdiction to

10 Id. ¶ 12. 11 Id. ¶ 71. 12 Id. ¶¶ 65-74. The Complaint also included a third claim for equitable subordination of USWM’s claim, if it is not disallowed. The Debtors have agreed to withdraw that claim. Adv. D.I. 18 at 1, n. 1. 13 Adv. D.I. 14. 14 Adv. D.I. 15, 18, 21, 22. 15 28 U.S.C. § 157(b)(1). 3 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.16 The Court finds that the claims in the Debtors’ Complaint are core claims subject to the Court’s jurisdiction because they involve an objection to a claim filed against the estate and counterclaims by the Debtors which are both premised on the Agreement and require the Court to decide which party breached that Agreement.17 Although USWM 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,18 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

16 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 part of the claim allowance process). 17 28 U.S.C. § 157(b)(2)(B) & (C), § 1334. 18 Adv. D.I. 14. See Stern v. Marshall, 564 U.S. 462, 503 (2011) (holding that while 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). 4 matters to the extent they do not constitute a final adjudication.19 That includes specifically the authority of the Court to determine whether the complaint states a plausible claim on which relief can be granted.20

III. STANDARD OF REVIEW A. Rule 12(b)(6)21 Rule 12(b)(6) provides for dismissal for “failure to state a claim upon which relief can be granted.”22 Under Rule 12(b)(6),

19 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 entered an order denying summary judgment because that order was not a final order) (citing Boyd v. King Par, LLC, No. 1:11–CV–1106, 2011 WL 5509873, at *2 (W.D. Mich. Nov. 10, 2011) (“[E]ven if there is uncertainty regarding the bankruptcy court’s ability to enter a final judgment . . . , that does not deprive the bankruptcy court of the power to entertain all pre-trial proceedings, including summary judgment motions.”)). 20 See Trinsum Grp., 467 B.R. at 738 (holding that bankruptcy court may enter interlocutory order dismissing fewer than all of the claims in an adversary complaint). 21 Fed. R. Civ. P. 12(b)(6). The applicable Federal Rules of Civil Procedure are incorporated into the Federal Rules of Bankruptcy Procedure. See Fed. R. Bankr. P. 7012. Therefore, citations herein are to the Federal Rules of Civil Procedure. 22 Fed. R. Civ. P.

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DMK Pharmaceuticals Corp. v. USWM, LLC, Counsel Stack Legal Research, https://law.counselstack.com/opinion/dmk-pharmaceuticals-corp-v-uswm-llc-deb-2025.