Vanda Pharmaceuticals, Inc. v. Food and Drug Administration

CourtDistrict Court, District of Columbia
DecidedFebruary 13, 2025
DocketCivil Action No. 2023-0280
StatusPublished

This text of Vanda Pharmaceuticals, Inc. v. Food and Drug Administration (Vanda Pharmaceuticals, Inc. v. Food and Drug Administration) 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
Vanda Pharmaceuticals, Inc. v. Food and Drug Administration, (D.D.C. 2025).

Opinion

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

VANDA PHARMACEUTICALS, INC.,

Plaintiff,

v.

UNITED STATES FOOD AND DRUG ADMINISTRATION, et al., Civil Action No. 23-280 (TSC)

Defendants,

and

TEVA PHARMACEUTICALS USA, INC.,

Intervenor-Defendant.

MEMORANDUM OPINION

Plaintiff Vanda Pharmaceuticals, Inc. has sued the Food and Drug Administration

(“FDA”); its Commissioner, Robert M. Califf; the Department of Health and Human Services; and

its Secretary, Xavier Becerra (collectively, “Defendants”). Am. Suppl. Compl. ¶¶ 9–13, ECF No.

44-1. Plaintiff alleges that Defendants violated the Administrative Procedure Act (“APA”) in

approving an application by Teva Pharmaceuticals USA, Inc. (“Teva”) to market the generic drug

tasimelteon, and in denying Plaintiff’s petition to revoke that approval. Id. ¶¶ 3–8. Teva

intervened as a defendant, see Feb. 5, 2023 Min. Order, and the parties have cross-moved for

summary judgment. For the reasons set forth below, the court will DENY Plaintiff’s Motion for

Summary Judgment, ECF No. 47; GRANT Teva’s Cross-Motion for Summary Judgment, ECF

No. 48; and GRANT Defendants’ Cross-Motion for Summary Judgment, ECF No. 50.

Page 1 of 29 I. BACKGROUND

A. Statutory and regulatory framework

The Federal Food, Drug, and Cosmetic Act (“FDCA”) requires that drug manufacturers

apply for and receive FDA approval before marketing any new drugs. 21 U.S.C. § 355(a). When

a drug is the first of its kind, applicants must submit extensive information about its safety,

effectiveness, composition, production, and labeling. Id. § 355(b)(1)(A). The FDA must carefully

evaluate that information—verifying its accuracy and considering the new drug’s risks and

benefits—before approving an application. Id. § 355(d). The process of securing approval for

such “pioneer” drugs is thus often “expensive and time-consuming.” Am. Bioscience, Inc. v.

Thompson, 269 F.3d 1077, 1079 (D.C. Cir. 2001).

In contrast, if a manufacturer seeks approval to market a generic version of a pioneer drug

that the FDA has already approved, it can do so through an abbreviated new drug application

(“ANDA”). 21 U.S.C. § 355(j). The ANDA need not provide independent evidence that the

proposed generic drug is safe or effective for its intended use. Instead, it must show that the generic

drug is “the same” as its pioneer counterpart. 21 U.S.C. § 355(j)(2)(A)(i)–(v), 355(j)(4)(B)–(G);

21 C.F.R. §§ 314.94, 314.127. That showing allows the generic manufacturer to “piggyback[] on

the original manufacturer’s evidence of safety and efficacy,” Teva Pharms., USA, Inc. v. Leavitt,

548 F.3d 103, 104 (D.C. Cir. 2008), and thus to “develop generic drugs inexpensively, without

duplicating the clinical trials already performed on the equivalent brand-name drug,” PLIVA, Inc.

v. Mensing, 564 U.S. 604, 612 (2011). “In creating this shortcut, Congress sought to encourage

the development of generic drugs to increase competition and lower prices,” Amgen Inc. v.

Hargan, 285 F. Supp. 3d 351, 358 (D.D.C. 2018) (citation and quotation marks omitted), thereby

increasing the availability of beneficial drugs without introducing any new dangers.

Page 2 of 29 By law, each ANDA must contain certain information demonstrating that the generic drug

is the same—and therefore as safe—as the pioneer one. For instance, the ANDA must show that

(1) the generic drug is “bioequivalent” to the pioneer drug; (2) its active ingredients, route of administration, strength and dosage form are “the same as” those of the pioneer drug; and (3) the inactive ingredients are not “unsafe for use under the conditions prescribed, recommended, or suggested in the labeling proposed for the drug.”

Zeneca, Inc. v. Shalala, 213 F.3d 161, 164 (4th Cir. 2000) (quoting 21 U.S.C. § 355(j)(4)(C), (D),

(H)).

Two ANDA requirements are particularly relevant here. First, the FDCA requires each

ANDA to “show that the labeling proposed for the new drug is the same as the labeling approved

for the [pioneer] drug.” 21 U.S.C. § 355(j)(2)(A)(v). That showing matters because the FDA’s

approval of the pioneer drug depends on whether it is “safe for use under the conditions prescribed,

recommended, or suggested in the proposed labeling thereof,” and whether its label is “false or

misleading.” Id. § 355(d). The FDCA does not require that showing, however, if there are label

“changes required . . . because the new drug and the [pioneer] drug are produced or distributed by

different manufacturers.” Id. § 355(j)(2)(A)(v). FDA regulations elaborate on that exception and

provide potential examples, explaining that such label changes “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.” 21 C.F.R. § 314.94(a)(8)(iv).

The FDA has interpreted the “different manufacturers” exception to permit generic

manufacturers to depart from the pioneer drug label where the original manufacturer had

“voluntarily adopted” certain standards “that are more onerous or rigorous than the standards FDA

Page 3 of 29 has determined are necessary.” Corrected Confidential J.A. at 357, ECF No. 59-1 (“J.A.”). 1 For

example, the FDA has approved generic labels that included “only one disposal method where the

[pioneer drug] labeling included two,” or “did not include halal and kosher certifications in their

labeling, where the [pioneer drug] did,” or “did not include a statement about peanut protein testing

included in the [pioneer drug] labeling.” Id. at 885. Likewise, the FDA has approved a generic

drug label that “included an ingredient safety warning that was not in the [pioneer drug] labeling,

where the generic manufacturer chose to formulate its product with a different inactive ingredient.”

Id. Finally, the FDA has “also considered differences in font, color, trade name, and other trade

dress to be permissible differences due to different manufacturers,” noting that “nearly all generic

drug product labeling” changes at least some of those aspects from the original brand-name drug

label. Id.

The second relevant ANDA requirement is related to the first: Each ANDA must “show

that the conditions of use prescribed, recommended, or suggested in the labeling proposed for the

new drug have been previously approved” for a pioneer drug. 21 U.S.C. § 355(j)(2)(A)(i).

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