Method Pharmaceuticals, LLC v. H2-Pharma, LLC

CourtDistrict Court, M.D. Alabama
DecidedAugust 8, 2025
Docket2:20-cv-00753
StatusUnknown

This text of Method Pharmaceuticals, LLC v. H2-Pharma, LLC (Method Pharmaceuticals, LLC v. H2-Pharma, LLC) is published on Counsel Stack Legal Research, covering District Court, M.D. Alabama primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Method Pharmaceuticals, LLC v. H2-Pharma, LLC, (M.D. Ala. 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE MIDDLE DISTRICT OF ALABAMA NORTHERN DIVISION

METHOD PHARMACEUTICALS, LLC, ) ) Plaintiff, ) ) v. ) CIVIL CASE NO. 2:20-cv-753-ECM ) [WO] H2-PHARMA, LLC, ) ) Defendant. )

MEMORANDUM OPINION and ORDER

I. INTRODUCTION

After nearly five years of litigation, the Court granted in part and denied in part Defendants H2-Pharma (“H2”) and Brooke Cantey’s (“Cantey) (collectively, “the Defendants”) motion for summary judgment on the three remaining claims in Plaintiff Method Pharmaceutical, LLC’s (“Method”) operative complaint.1 (Doc. 334).2 Method now asks the Court to partially reconsider its summary judgment Opinion (“the Opinion”) under Federal Rule of Civil Procedure 59(e), which the Court construes as a motion under Rule 54(b). Method claims it lacked notice from the Defendants’ briefing of the grounds the Court would use to grant the motion—materiality. (Doc. 339).3 Method now seeks to present additional evidence and argument regarding materiality to the Court. Method’s

1 Specifically, the Court granted summary judgment on Counts I and III of the operative (second amended) complaint but denied it for Count II. 2 For clarity, the Court refers to the docket and page numbers generated by CM/ECF. 3 The Court dismissed Cantey from the case, but Method does not challenge the Court’s ruling regarding Cantey in this motion. (Doc. 346 at 19 n.7). motion for partial reconsideration is fully briefed and ripe for review. After careful consideration of the arguments presented and a review of the evidence submitted at

summary judgment, the Court finds the motion is due to be DENIED. II. JURISDICTION AND VENUE The Court has original subject matter jurisdiction over the claims in this proceeding pursuant to 28 U.S.C. § 1331. The parties do not contest personal jurisdiction or venue, and the Court concludes that venue properly lies in the Middle District of Alabama. See 28 U.S.C. § 1391.

III. LEGAL STANDARD

Method moves the Court under Rule 59(e) to reconsider the Opinion. But Rule 59(e) only applies to judgments, which is “a decree and any order from which an appeal lies,” FED. R. CIV. P. 54(a). Because Count II of the operative complaint remains pending, the Court did not enter a final judgment with the Opinion, see Lind v. United Parcel Serv., Inc., 254 F.3d 1281, 1284 n.4 (11th Cir. 2001); Gen. Television Arts, Inc. v. S. Railway Co., 725 F.2d 1327, 1331, n.5 (11th Cir. 1984), so the Opinion is “an interlocutory—i.e., nonfinal—order.” See Holmes v. Fresenius Kidney Care of Tuskegee, 2023 WL 2413993, at *1 (M.D. Ala. Mar. 8, 2023) (citing Tufts v. Hay, 977 F.3d 1204, 1210 (11th Cir. 2020)).4 Although the Federal Rules do not specifically provide for

challenging an interlocutory order, Rule 54(b) allows a district court to “revise[] at any time” “any order or other decision . . . that adjudicates fewer than all the claims . . . before

4 Here, and elsewhere in this Memorandum Opinion, the Court cites nonbinding authority. While the Court recognizes that these cases are nonprecedential, the Court finds them persuasive. the entry of a judgment adjudicating all the claims . . . .” FED. R. CIV. P. 54(b). “Furthermore, a district court has broad and ‘plenary power’ over its interlocutory orders,

and ‘may therefore reconsider, revise, alter, or amend that order at any time prior to final judgment.’” Holmes, 2023 WL 2413993, at *1 (quoting Hardin v. Hayes, 52 F.3d 934, 938 (11th Cir. 1995)). Because Rule 59(e) does not apply, the Court does not have to adhere to the standard applicable to a motion to reconsider a final judgment under Rule 59(e). See Hertz Corp. v. Alamo Rent-A-Car, Inc., 16 F.3d 1126, 1132 (11th Cir. 1994) (“The strictures of Rule 59(e)

remain dormant, however, until a final judgment has been entered.”). But “courts in this Circuit have turned to [the Rule 59(e)] standard for guidance in reconsideration” of an interlocutory order. See Holmes, 2023 WL 2413993, at *1 (citing cases). Under Rule 59(e), “[t]he only grounds for granting [the] motion are newly-discovered evidence or manifest errors of law or fact.” In re Kellogg, 197 F.3d 1116, 1119 (11th Cir. 1999). The Eleventh

Circuit, however, has also “indicated that Rule 54(b) takes after Rule 60(b),” Herman v. Hartford Life & Acc. Ins. Co., 508 F. App’x 923, 927 n.1 (11th Cir. 2013) (citing Fernandez v. Bankers Nat’l Life Ins. Co., 906 F.2d 559, 569 (11th Cir. 1990)), and “is appropriate to correct manifest errors of law or fact.” Id. at 927 (citing FED. R. CIV. P. 60(b)). Still, “reconsideration of an order is an extraordinary remedy and is employed

sparingly.” Hadley v. Coffee Cnty. Comm’n, 2022 WL 2057762, at *2 (M.D. Ala. June 7, 2022) (citation omitted). “Motions to amend should not be used to raise arguments which could, and should, have been made before the judgment was issued.” O’Neal v. Kennamer, 958 F.2d 1044, 1047 (11th Cir. 1992). Indeed, a party may not use a motion to reconsider “to relitigate old matters, raise arguments or present evidence that could have been raised prior to the entry of judgment.” Arthur v. King, 500 F.3d 1335, 1343 (11th Cir.

2007). IV. FACTS

This case has a long history, and the Court declines to add record facts here. Instead, the Court relies on the facts presented in the Opinion. (See doc. 334 at 2–15). But, for clarity, the Court summarizes the Opinion and its reasoning. At summary judgment, three claims were before the Court: (1) false advertising against the Defendants (serialization) (Count I), (2) false advertising against H2 (Food and Drug Administration (“FDA”) approval) (Count II), and (3) contributory false advertising against the Defendants (serialization) (Count III). The Court granted summary judgment on Counts I and III (serialization) but denied it on Count II because H2 failed to carry its burden to show there was no genuine dispute of material fact about FDA approval. (See doc. 334 at 22–29). In

the Opinion, the Court found that serialization was not material to the purchasing decisions of participants in the fluoride pharmaceutical market and described serialization as a detailed product identifier. (Id. at 22–25). As part of its reasoning, the Court noted that Method did not argue materiality in its summary judgment response and failed to create a genuine dispute of material fact to survive the Defendants’ motion on Counts I and III. (Id.

at 25). The Court also found specific evidence regarding failure-to-supply penalties issued by Walgreens supported Method’s standing to pursue its Lanham Act claims but did not warrant denying summary judgment. (See id. at 19–20, 25 n.17). As it has before, the Court emphasizes the underlying issue in this case: whether H2’s representations on its label led market participants to believe that its products were

serialized in accordance with the Drug Supply Chain Security Act (“DSCSA”), causing consumers to purchase H2’s products because they incorrectly believed they were serialized. V.

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Bluebook (online)
Method Pharmaceuticals, LLC v. H2-Pharma, LLC, Counsel Stack Legal Research, https://law.counselstack.com/opinion/method-pharmaceuticals-llc-v-h2-pharma-llc-almd-2025.