Novartis Pharmaceuticals Corporation v. Becerra

CourtDistrict Court, District of Columbia
DecidedAugust 13, 2024
DocketCivil Action No. 2024-2234
StatusPublished

This text of Novartis Pharmaceuticals Corporation v. Becerra (Novartis Pharmaceuticals Corporation v. Becerra) 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
Novartis Pharmaceuticals Corporation v. Becerra, (D.D.C. 2024).

Opinion

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

NOVARTIS PHARMACEUTICALS CORPORATION,

Plaintiff,

v.

XAVIER BECERRA, et al., No. 24-cv-02234 (DLF) Defendants.

and

MSN PHARMACEUTICALS INC., et al.,

Intervenor-Defendants.

MEMORANDUM OPINION

Plaintiff Novartis Pharmaceuticals Corporation brings this action against the Secretary of

Health and Human Services (“HHS”) and the Commissioner of the Food and Drug Administration

(“FDA”) for injunctive relief. Novartis alleges that FDA unlawfully approved an application by

MSN Pharmaceuticals Inc. and MSN Laboratories Private Ltd. (“MSN”) to market a generic

version of Novartis’s heart failure medication ENTRESTO (generic combination

sacubitril/valsartan). MSN intervened as defendant. Before the Court is the plaintiff’s motion for

a temporary restraining order and/or preliminary injunction to stay FDA’s approval of MSN’s drug

application. Dkt. 3. For the reasons that follow, the Court will deny Novartis’s motion for a

preliminary injunction. I. BACKGROUND

A. Statutory Background

To obtain FDA approval to market a new, brand-name drug, a manufacturer must submit

a New Drug Application (NDA) containing clinical data from studies demonstrating that the drug

is safe and effective. See 21 U.S.C. § 355(b)(1). The brand-name manufacturer often holds patents

for the drug product, as well as patents for methods-of-use of the drug. FDA maintains a

publication, colloquially referred to as the “Orange Book,” which lists active pharmaceutical

patents including method-of-use patents.

After the period of patent exclusivity expires for a drug product, other manufacturers may

obtain FDA approval to market a generic version through an Abbreviated New Drug Application

(ANDA). See 21 U.S.C. § 355(j). ANDAs need not include independent clinical data of safety or

effectiveness; the applicant need only establish the generic drug is “the same as” a previously

approved brand-name reference drug. See id. § 355(j)(2). To demonstrate “same”-ness, the

applicant must prove the generic is (1) the pharmaceutical equivalent of, (2) labeled for the same

conditions of use as, and (3) bioequivalent to the reference drug. See id. § 355(j)(2)(A). ANDA

applicants that seek approval for generic drugs with use-cases listed in the Orange Book must file

either a “paragraph IV certification” challenging the validity of listed patents, id. §

355(j)(2)(A)(vii)(IV), or a “section viii statement” certifying the applicant does not seek to market

the drug for use-cases covered by patent, id. § 355(j)(2)(A)(viii). Section viii ANDA applicants

may “carve out” patented use-cases from the generic’s label, subject to statutory and regulatory

constraints.

FDA regulations supplement the statutory scheme by, as relevant here, clarifying the “same

labeling” requirement. Id. § 355(j)(2)(A). FDA regulations provide that a generic label may differ

2 from a reference label when a drug is produced by a “different manufacturer[],” in order to address

differences in marketing exclusivity or patent rights:

Such differences between the applicant's proposed labeling and labeling approved for the reference listed drug may include differences in expiration date, formulation, bioavailability, or pharmacokinetics, labeling revisions made to comply with current FDA labeling guidelines or other guidance, or omission of an indication or other aspect of labeling protected by patent or accorded exclusivity under section 505(j)(5)(F) of the Federal Food, Drug, and Cosmetic Act.

21 C.F.R. § 314.94(a)(8)(iv). However, the labeling differences may “not render the proposed

drug product less safe or effective than the listed drug for all remaining, nonprotected conditions

of use.” Id. § 314.127(a)(7).

B. Factual Background

In 2015, FDA approved the heart failure drug ENTRESTO. See Pl.’s Ex. A (ENTRESTO

Labeling) § 1.1, Dkt. 1-1. Since that time, Novartis has marketed ENTRESTO without generic

competition and has generated over $10.5 billion in revenue in the United States. Compl. ¶ 79,

Dkt. 1. Novartis still owns several ENTRESTO-related method-of-use patents that hinder generic

entry in two ways. First, Novartis patents No. 9,517,226; No. 9,937,143; and No. 11,135,192

purport to cover use of the drug to treat a certain population of chronic heart failure patients,

classified as those with “preserved ejection fraction.” See id. ¶ 40. Second, Novartis patent

No. 11,058,667 purports to cover a specific dosing regimen of the drug. See id. ¶ 39.

In September 2022, Novartis submitted a citizen petition requesting that FDA refrain from

approving any ENTRESTO-related ANDA that would carve out labeling language related to those

patented methods. Pl.’s Mot. for TRO at 10–11. Novartis raised essentially the same arguments

that it does in the instant motion, namely, that the two carve outs violate both the Federal Food

Drug and Cosmetic Act and FDA’s regulations and present safety and efficacy risks. On July 24,

2024, FDA denied Novartis’s citizen petition in a 45-page letter detailing why the carveouts would

3 be proper under statute and regulation and would not risk the drug’s safety or efficacy. Pl.’s Ex.

H, Dkt. 1-8. That same day, FDA approved MSN’s ANDA No. 213748 for generic

sacubitril/valsartan, which contains the disputed carveouts. The carveouts are described below.

1. Indication Carveout

ENTRESTO’s indication currently reflects that it is approved to treat all adult patients with

chronic heart failure. Chronic heart failure patients are sometimes classified by a diagnostic

criterion called left ventricular ejection fraction (LVEF)—that is, the ability of the left heart

ventricle to pump out blood with each contraction. See Pl.’s Ex. I § 14, Dkt. 1-9. At the time of

ENTRESTO’s approval by FDA, reduced ejection fraction patients (HFrEF) were understood to

suffer from a more severe form of the disease. Pl.’s Mot. for TRO at 6. ENTRESTO was initially

approved based on the results of a clinical trial that enrolled only reduced ejection fraction patients.

Id. After ENTRESTO’s approval, Novartis completed another clinical trial evaluating the drug’s

effectiveness on patients with only mildly-reduced or normal LVEF—that is, preserved ejection

fraction patients. Pl.’s Ex. F (Labeling Carve-Out Citizen Petition) at 7–8, Dkt. 1-6. That trial

demonstrated that chronic heart failure patients with preserved ejection fraction (HFpEF) also

benefitted from ENTRESTO, albeit less so than reduced ejection fraction patients. Accordingly,

in 2021 FDA approved a supplement to ENTRESTO’s indication reflecting the drug’s broader

application. See Pl.’s Ex. I § 1.1. ENTRESTO’s indication currently reads:

ENTRESTO is indicated to reduce the risk of cardiovascular death and hospitalization for heart failure in adult patients with chronic heart failure. Benefits are most clearly evident in patients with left ventricular ejection fraction (LVEF) below normal.

LVEF is a variable measure, so use clinical judgment in deciding whom to treat.

Pl.’s Ex. A § 1.1, Dkt. 1-1.

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

Related

Skidmore v. Swift & Co.
323 U.S. 134 (Supreme Court, 1944)
Cobell, Elouise v. Norton, Gale
391 F.3d 251 (D.C. Circuit, 2004)
Chaplaincy of Full Gospel Churches v. England
454 F.3d 290 (D.C. Circuit, 2006)
Sherley v. Sebelius
644 F.3d 388 (D.C. Circuit, 2011)
Arrow Air, Inc. v. United States
649 F. Supp. 993 (District of Columbia, 1986)
Bristol-Myers Squibb Co. v. Shalala
923 F. Supp. 212 (District of Columbia, 1996)
Varicon International v. Office of Personnel Management
934 F. Supp. 440 (District of Columbia, 1996)
Qualls v. Rumsfeld
357 F. Supp. 2d 274 (District of Columbia, 2005)
Biovail Corp. v. U.S. Food & Drug Administration
448 F. Supp. 2d 154 (District of Columbia, 2006)
Astellas Pharma US, Inc. v. Food & Drug Administration
642 F. Supp. 2d 10 (District of Columbia, 2009)
Mylan Laboratories, Inc. v. Leavitt
484 F. Supp. 2d 109 (District of Columbia, 2007)
Mylan Laboratories Limited v. Food and Drug Administration
910 F. Supp. 2d 299 (District of Columbia, 2012)
League of Women Voters v. Brian Newby
838 F.3d 1 (D.C. Circuit, 2016)
Mdewakanton Sioux Indians of Minnesota v. Jewell
255 F. Supp. 3d 48 (District of Columbia, 2017)

Cite This Page — Counsel Stack

Bluebook (online)
Novartis Pharmaceuticals Corporation v. Becerra, Counsel Stack Legal Research, https://law.counselstack.com/opinion/novartis-pharmaceuticals-corporation-v-becerra-dcd-2024.