United HealthCare Services, Inc. v. Merck & Co., Inc.

CourtDistrict Court, D. Minnesota
DecidedFebruary 25, 2025
Docket0:20-cv-01909
StatusUnknown

This text of United HealthCare Services, Inc. v. Merck & Co., Inc. (United HealthCare Services, Inc. v. Merck & Co., Inc.) is published on Counsel Stack Legal Research, covering District Court, D. Minnesota primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
United HealthCare Services, Inc. v. Merck & Co., Inc., (mnd 2025).

Opinion

UNITED STATES DISTRICT COURT DISTRICT OF MINNESOTA CIVIL NO.: 20-1909(DSD/DTS)

United HealthCare Services, Inc.

Plaintiff,

v. ORDER

Merck & Co., Inc., Merck Sharp & Dohme Corp., Schering-Plough Corp., Schering Corp., MSP Singapore Co., LLC, Glenmark Pharmaceuticals, Ltd., Glenmark Pharmaceuticals Inc., USA, Par Pharmaceutica, Inc.,

Defendants.

This matter is before the court upon the motion to dismiss by defendants Merck & Co., Inc., Merck Sharp & Dohme Corp., Schering- Plough Corp., Schering Corp., MSP Singapore Co., LLC, Glenmark Pharmaceuticals, Ltd., Glenmark Pharmaceuticals Inc., USA, and Par Pharmaceutica, Inc. Based on a review of the file, record, and proceedings herein, and for the following reasons, the motion is denied.

BACKGROUND1

1 This case is factually and legally complex and has been ongoing since 2020. To streamline matters, the court will discuss only those facts necessary to the outcome of the narrow issues presented. This antitrust action arises from alleged anticompetitive

conduct involving the sale of defendant Merck, & Co.’s lipid- lowering drugs Zetia and Vytorin. Plaintiff United HealthCare Services, Inc. (UHS) contends that defendants’ alleged misconduct caused overcharges for Zetia and Vytorin, a combination pill comprised of Zetia and simvastatin (generic Zocor). Am. Compl. ¶¶ 1, 10. UHS seeks recovery for all overcharges it incurred in connection with paying for branded and generic Zetia and Vytorin products prescribed and dispensed to its insureds.2 Id. ¶ 10. I. The Parties UHS “services prescription drug managed care programs provided to members and beneficiaries under insurance plans offered by UHS’s subsidiaries and affiliates.” Id. ¶ 6. As such,

UHS is the “centralized and primary contracting entity responsible for payments made for prescription drugs dispensed to UnitedHealthcare Insureds throughout the country,” including Zetia and Vytorin. Id. Defendant Merck & Co., Inc. is the manufacturer of Zetia and Vytorin and the holder of underlying patents. Id. ¶¶ 2, 83-99. It is the parent corporation of defendants Merck Sharp & Dohme

2 For ease of reference, the court’s use of the term UHS will include UHS’s subsidiaries and affiliates. See id. ¶¶ 7-9.

2 Corporation and MSP Singapore Company LLC. Id. ¶¶ 13, 17.3 The

distinctions among the defendants related to Merck & Co., Inc. are not relevant to this motion. As a result, the court will refer to those defendants collectively as “Merck.” Defendant Glenmark Pharmaceuticals Inc., USA is a wholly owned subsidiary of defendant Glenmark Pharmaceuticals Limited. Id. ¶ 19. II. Underlying Settlement To understand this case, the court must provide some explanation of a patent infringement suit between Merck (then Schering) and Glenmark relating to the drugs at issue here. In 2006, defendant Glenmark, a generic drug manufacturer, sought FDA approval to market a generic version of Zetia. Id.

¶ 119. Glenmark notified Merck of its FDA filing and claimed that Merck’s Zetia-related patents were invalid, unenforceable, and not infringed by Glenmark’s generic product. Id. ¶ 122. Soon thereafter, Merck filed suit against Glenmark in the District of New Jersey alleging patent infringement. Id. ¶ 123. Glenmark

3 Merck & Co., Inc. acquired defendant Schering-Plough Corporation in 2009. Merck & Co., Inc. then merged into defendant Schering-Plough Corporation, which subsequently changed its name to Merck & Co., Inc. The company formerly known as Merck & Co. Inc. changed its name to defendant Merck Sharp & Dohme Corporation. Id. ¶¶ 14-16.

3 asserted counterclaims. Id. ¶ 127. Contentious litigation ensued.

Four years later, and on the eve of trial, the parties settled their dispute. Id. ¶ 156. UHS refers to the settlement as an illegal reverse payment agreement. UHS alleges that Glenmark agreed to “forego its meritorious patent challenge and delay its launch of generic Zetia for nearly five years4 in exchange for a payment from Merck in the form of Merck’s promise not to launch an authorized generic version of Zetia that would compete with Glenmark’s generic product during Glenmark’s 180- day period of first-filer exclusivity.”5 Id. ¶¶ 2; 158, 170-71. This, according to UHS, profited both Merck and Glenmark enormously. UHS alleges that, absent the agreement, Merck would have lost 80% of sales on branded Zetia and a “substantial portion”

of its sales of Vytorin. Id. ¶ 186. Instead, UHS contends, Merck reaped “billions of dollars” under the agreement by delaying generic alternatives from entering the market, which allowed Merck to set “higher than competitive prices” for the drugs. Id. ¶ 187. In turn, Glenmark benefitted by being able to launch its generic form of Zetia with no generic competitors. Id. ¶ 188. UHS

4 The agreement permitted Glenmark to launch its generic form of Zetia on December 12, 2016. Id. ¶ 170. 5 UHS alleges that the agreement targeted Vytorin, as well as Zetia. Id. ¶ 145.

4 estimates that Glenmark may have earned as much as $500 million

due to the reverse payment agreement. Id. ¶¶ 191-92. III. This Action In September 2020, UHS commenced this action against defendants alleging that the reverse payment agreement violated the Sherman Act, 15 U.S.C. § 1; the Clayton Act, 15 U.S.C. § 2; the Minnesota Antitrust Law, Minn. Stat. §§ 325D.49, 325D.52; and various other states’ antitrust and consumer protection laws (pleaded in the alternative). See Compl. ¶¶ 250-93. UHS also brought a claim for unjust enrichment. Id. ¶¶ 294-313. Soon thereafter, the case was transferred to the Eastern District of Virginia to join the ongoing multidistrict litigation, titled In re: Zetia (Ezetimebe) Antitrust Litigation, MDL No. 2836, for

consolidated pretrial proceedings. ECF No. 6. In 2022, during the MDL proceedings, UHS filed an amended complaint, adding claims relating to Vytorin, which were not raised in the original complaint. See Am. Compl., Greenblatt Decl. Ex. B. Specifically, UHS claimed for the first time that the reverse payment agreement not only resulted in significant overcharges for Vytorin as well. See id. ¶¶ 1, 3, 145, 186-87, 230. Defendants moved to dismiss the Vytorin claims. At the hearing on the motion, the presiding judge expressed skepticism, opining that the casual

5 chain may be too attenuated to establish liability. Greenblatt

Decl. Ex. A, at 34-35, 41-42, 54-55. He also noted, however, that the amended complaint may have plausibly alleged the Vytorin claims for purposes of a motion to dismiss. Id. ¶¶ 56-57. On December 23, 2023, the MDL panel remanded the case to this court after concluding pretrial proceedings and without formally ruling on the whether the Vytorin claims could proceed. ECF No. 8; Greenblatt Decl. Ex. A. UHS refiled its amended complaint in this case on May 17, 2024, which the court accepted as the operative complaint. Greenblatt Decl. ¶ 4; ECF No. 57. Defendants now move to dismiss the amended complaint in part, arguing that (1) UHS lacks standing to bring claims based on Vytorin sales; (2) UHS agreed to be bound by the MDL court’s dismissal of per se antitrust violation claims;6 and (3) the non-

Minnesota state-law claims fail to state a plausible claim. Defendants do not move to dismiss its primary theory of liability relating to Zetia sales.

6 During briefing, UHS conceded that its per se theory claims were dismissed under the parties’ stipulation in the MDL proceedings. ECF No. 63, at 54-55. As a result, the court need not address that issue.

6 DISCUSSION

I.

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