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Astrazeneca Ab et. al. v. Watson Laboratories, Inc. - Florida et. al.

Astrazeneca Ab et. al. v. Watson Laboratories, Inc. - Florida et. al.

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Published by PriorSmart
Official Complaint for Patent Infringement in Civil Action No. 3:13-cv-01669-JAP-TJB: Astrazeneca Ab et. al. v. Watson Laboratories, Inc. - Florida et. al. Filed in U.S. District Court for the District of New Jersey, the Hon. Joel A. Pisano presiding. See http://news.priorsmart.com/-l7QK for more info.
Official Complaint for Patent Infringement in Civil Action No. 3:13-cv-01669-JAP-TJB: Astrazeneca Ab et. al. v. Watson Laboratories, Inc. - Florida et. al. Filed in U.S. District Court for the District of New Jersey, the Hon. Joel A. Pisano presiding. See http://news.priorsmart.com/-l7QK for more info.

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Published by: PriorSmart on Mar 20, 2013
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 John E. FlahertyJonathan M.H. ShortMcCARTER & ENGLISH, LLPFour Gateway Center100 Mulberry StreetNewark, New Jersey 07102(973) 622-4444
 Attorneys for Plaintiffs AstraZeneca AB, Aktiebolaget Hässle, AstraZeneca LP, KBI Inc., and KBI-E Inc.
Of Counsel:Henry J. RenkBruce C. HaasJoshua I. RothmanFITZPATRICK, CELLA, HARPER& SCINTO1290 Avenue of the AmericasNew York, New York 10104-3800(212) 218-2100Einar StoleCOVINGTON & BURLING LLP1201 Pennsylvania Avenue, N.W.Washington, D.C. 20004-2401(202) 662-6000
UNITED STATES DISTRICT COURTFOR THE DISTRICT OF NEW JERSEY
ASTRAZENECA AB, AKTIEBOLAGETHÄSSLE, ASTRAZENECA LP, KBI INC.,and KBI-E INC.,Plaintiffsv.WATSON LABORATORIES, INC. –FLORIDA, WATSON PHARMA, INC., andACTAVIS, INC.,Defendants.Civil Action No. __________________COMPLAINT FOR PATENTINFRINGEMENTAND CERTIFICATION PURSUANT TOLOCAL CIVIL RULE 11.2
 
 1
COMPLAINT FOR PATENT INFRINGEMENT
AstraZeneca AB, Aktiebolaget Hässle, AstraZeneca LP, KBI Inc., and KBI-E Inc.(collectively, “Plaintiffs”), for their Complaint against Watson Laboratories, Inc. – Florida,Watson Pharma, Inc., and Actavis, Inc. (collectively, “Defendants”), hereby allege as follows:
THE PARTIES
1.
 
Plaintiff AstraZeneca AB is a company organized and existing underthe laws of Sweden, having its principal place of business at Södertälje, Sweden. AstraZenecaAB was a corporate name change from Astra Aktiebolaget.2.
 
Plaintiff Aktiebolaget Hässle is a company organized and existingunder the laws of Sweden, having its principal place of business at Mölndal, Sweden.3.
 
Plaintiff AstraZeneca LP is a limited partnership organized under thelaws of Delaware, having its principal place of business at Wilmington, Delaware. AstraZenecaLP holds approved New Drug Application No. 021153 from the United States Food and DrugAdministration (“FDA”) for a delayed-release esomeprazole magnesium formulation that it sellsunder the name NEXIUM®.4.
 
Plaintiff KBI Inc. (“KBI”) is a Delaware corporation having itsprincipal place of business at Whitehouse Station, New Jersey.5.
 
Plaintiff KBI-E Inc. (“KBI-E”) is a Delaware corporation having itsprincipal place of business at Wilmington, Delaware.6.
 
KBI and KBI-E have exclusive rights in the United States to thepatents-in-suit.7.
 
Upon information and belief, Defendant Watson Laboratories, Inc. –Florida (“Watson Laboratories”) was formerly known as Andrx Pharmaceuticals, Inc. (“Andrx
 
 2Pharmaceuticals”). Upon information and belief, Watson Laboratories is a corporationorganized and existing under the laws of Florida, having its principal place of business at 4955Orange Drive, Davie, Florida 33314. Upon information and belief, Watson Laboratories is in thebusiness of,
inter alia
, developing, manufacturing, and obtaining regulatory approval of genericcopies of branded pharmaceutical products throughout the United States, including within thisdistrict.8.
 
Upon information and belief, Defendant Watson Pharma, Inc.(“Watson Pharma”) is a corporation organized and existing under the laws of Delaware, havingits principal place of business at Morris Corporate Center III, 400 Interpace Parkway,Parsippany, New Jersey 07054. Upon information and belief, Watson Pharma is in the businessof,
inter alia
, selling and distributing generic copies of branded pharmaceutical products in NewJersey and throughout the United States, including some that are manufactured by WatsonLaboratories and/or for which Watson Laboratories is the named applicant of the approvedANDAs.9.
 
Upon information and belief, Defendant Actavis, Inc. (“Actavis”)was formerly known as Watson Pharmaceuticals, Inc. (“Watson Pharmaceuticals”) until on oraround January 24, 2013. Actavis is a corporation organized and existing under the laws of Nevada, having its principal place of business at Morris Corporate Center III, 400 InterpaceParkway, Parsippany, New Jersey 07054. Upon information and belief, Actavis is in thebusiness of,
inter alia
, developing, manufacturing, obtaining regulatory approval, marketing,selling, and distributing generic copies of branded pharmaceutical products throughout theUnited States, including within this district, through its own actions and through the actions of itsagents and subsidiaries, including at least Watson Laboratories and Watson Pharma.

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