Federal Trade Commission v. Surescripts, LLC

CourtDistrict Court, District of Columbia
DecidedJanuary 17, 2020
DocketCivil Action No. 2019-1080
StatusPublished

This text of Federal Trade Commission v. Surescripts, LLC (Federal Trade Commission v. Surescripts, LLC) is published on Counsel Stack Legal Research, covering District Court, District of Columbia primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Federal Trade Commission v. Surescripts, LLC, (D.D.C. 2020).

Opinion

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

FEDERAL TRADE COMMISSION,

Plaintiff, v Civil Action No. 19-1080 (JDB) SURESCRIPTS, LLC,

Defendant.

MEMORANDUM OPINION

The Federal Trade Commission petitions this Court for equitable reliei including a

permanent injunction and monetary relief, against Surescripts , LLC pursuant to Section 13(b) of

the FTC Act. See 15 U.S.C. $ 53(b). The FTC alleges that Surescripts has violated Section 2 of

the Sherman Act by maintaining a monopoly in two markets-electronic prescription routing and

eligibility (explained below)-through anticornpetitive conduct, including an exclusive loyalty-

based pricing policy. Surescripts moves to dismiss, arguing (1) that the Court lacks subject matter

jurisdiction under Section l3(b) of the FTC Act, and (2) that the FTC fails to state a claim under

Section 2 of the Sherman Act because it does not allege either that Surescripts employed predatory

pricing or that Surescripts's market behavior violated the rule of reason. For the reasons explained

below, the Court will deny Surescripts's motion.

BlcxcRouNt

At the pleadings stage, the Court assumes the facts alleged in the complaint are true and

presents them in the light most favorable to the plaintiff-here, the FTC. Felter v. Kempthorne,

473 F.3d 1255,1257 (D.C. Cir. 2007). Sulescripts is a health information technology company

operating in two complementary markets: electronic prescription routing ("routing") and

1 eligibility, collectively known as "e-prescribing." Compl. fol lnjunctive & Other Equitable Relief

("Compl.") [ECF No. 1] 11 1. Routing involves the transmission of prescription-related data from

a prescriber to a pharmacy via the prescriber's electronic health record ("EHR") system. Id.

Eligibility involves the transmission of a patient's forrnulary and benefit information fi'om a payer

(often the patient's pharmacy benefit manager ("PBM")) to a prescriber's EHR. Id. Surescripts

charges pharmacies a fee for each routing transaction and charges PBMs a fee for each eligibility

transaction. Id. T 49.

According to the FTC, Surescripts mainlains at least a 95Yo share (by transaction volume)

in each market using various anticompetitive measures. Id. lifl 2-3. Beginning around 2009,

Surescripts implemented a pricing policy that rewarded "loyal" (i.e., exclusive) customers with

lower prices. Id. T 2. "To be considered exclusive, Surescripts requires that a pharmacy . . . route

100% of its transactions ttn'ough and only through the Surescripts network." Id. 1l 66 (internal

quotation marks omitted). "The same structure exists for PBMs in eligibility." Id. 1167. For

routing, the cost to non-loyal customers varies by volume, but can be as high as I more than

for loyal customers; for eligibility, as high as | *o... Id. T1l 70_71. Surescripts structured its

contracts with EHR providers such that loyalty in either the routing or eligibility markets resulted

in an incentive payment to the EHR provider of I of the fees paid by the customers in that

market; exclusivity in both markets resulted in an incentive payrnent of ! of the fees from both

markets. Id. n 77 .

The FTC contends that "[t]hose effectively exclusive contracts foreclosed at least 7}Yo of

each market, eliminating multiple competitive attempts from other companies. . . that offered

lower prices and greater innovation." Id. 113. The FTC notes that these loyalty contracts are

especially effective at excluding competition in the routing and eligibility markets because, given

2 Surescripts's dominant position, almost all market entrants must compete for customers who

already use Surescripts. Id. 1132. To gain a foothold in either narket, entrants must convince

customers to engage in "multihoming," or the simultaneous use of Surescripts as well as one or

more competitors. Id. The FTC alleges that, by raising the cost of multihoming, Surescripts

hindered customers' ability to "multihome" and "significantly elevat[ed] the critical mass fof

initial customers] a Surescripts cornpetitor would need to become a viable network in'either routing

or eligibility." Id.

Beyond the loyalty program, Surescripts employed "threats and other non-merits based

competition" to keep its customers from working with its competitors. Id. fl 4. For instance, when

a competitor, Emdeon, attempted to enter the market through contracts with Allscripts, a large

EHR, Surescripts relied on its market power to force Allscripts into exclusive contracts that

prevented a renewal of Allscripts's contract with Emdeon. Id. ll'1T I l0-1 1. Surescripts also entered

into a non-compete agreement with another competitor, RelayHealth, which prevented

RelayHealth from capturing up to 15-20o/o of the routing market. Id. T 5; see also id. TT 88-99.

The FTC alleges that these exclusive arrangements have allowed Superscripts to impose

heightened prices on large portions of the markets, see. e.q., id. llfl 187-95, and have stifled

innovation and reduced quality in the two e-prescribing markets, id. lTT 196*215.

Surescripts moves to dismiss the FTC's complaint, arguing that this case is both

procedurally and substantively defective. Surescripts, LLC's Mot. to Dismiss Compl. ("Def.'s

Mot.") [ECF No. 32] 1T'1T 1-3. First, Surescripts argues that the Court lacks subject matter

jurisdiction over the request for a permanent injunction because the FTC cannot establish that this

case is "proper" under Section 13(b) of the FTC Act. Id. T 1; see also 15 U.S.C. $ 53(b). Second,

Surescripts argues that the FTC's complaint fails to state a claim under Section 2 of the Sherman

J Act because it does not allege that the prices offered by Surescripts were predatory or that

Surescripts's market practices violated the rule of reason. Def.'s Mot. flfl 2-3.

Lpcal Sra¡lnano 'When considering a motion to dismiss under Federal Rule of Civil Procedure 12(b)(6), a

couft presumes the truth of a complaint's factual allegations, though it is "not bound to accept as

true a legal conclusion couched as a factual allegation." Bell Atl. Corp. v. Twombly, 550 U.S.

544,555 (2007) (internal quotation omitted). The court then asks whether the facts alleged suffice

"to state a claim to relief that is plausible on its face." Aú*eqqhal, 556 U.S. 662,678 (2009)

(internal quotation omitted). The court considers "facts alleged in the complaint, any documents

either attached to or incorporated in the complaint and matters of which fthe Court] may take

judicial notice." Mpo), v. Rhee, 758 F.3d 285,291 n.l (D.C. Cir.2014) (internal quotation

omitted).

Under Rule l2(b)(l), a court has an affirmative obligation to ensure that it is acting within

the scope of its jurisdictional authority. Grand Lodge of the Fraternal Order of Police v. Ashcroft,

185 F. Supp. 2d9,13 (D.D.C. 2001). "[The] court must dismiss a case when it lacks subject matter

jurisdiction." Randolph v. ING Life Ins. & Annuity Co., 486 F. Supp. 2d l, 4 (D.D.C. 2007).

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Federal Trade Commission v. Surescripts, LLC, Counsel Stack Legal Research, https://law.counselstack.com/opinion/federal-trade-commission-v-surescripts-llc-dcd-2020.