On information and belief, personal jurisdiction over Sandoz is also proper because Sandoz has sought affirmative relief in this jurisdiction by answering Complaints andfiling counterclaims, and because Sandoz has employed Delaware counsel to assist in obtainingthat relief.11.
Sandoz has also previously availed itself of this jurisdiction for the purpose of litigating its patent suits.
Sandoz Inc. v. Pfizer Inc
., C.A. No. 10-104 (D. Del.). Inaddition, Sandoz has previously been sued in this District and has not contested personal jurisdiction.
Glaxosmithkline Intellectual Property Management Ltd. et al. v. Sandoz, Inc
., C.A. No. 11-01284 (D. Del.);
Aventis Pharma S.A. v. Sandoz Inc.
, C.A. No. 11-043 (D.Del.).12.
Venue is proper in this judicial District pursuant to 28 U.S.C. §§ 1391 and1400(b).
Genzyme is the holder of New Drug Application (“NDA”) No.
022311, whichrelates to Plerixafor solution 20 mg/mL for subcutaneous injection. On December 15, 2008, theFDA approved the marketing of the drug product described in NDA No. 022311 for use incombination with granulocyte-colony stimulating factor (
) to mobilize hematopoieticstem cells to the peripheral blood for collection and subsequent autologous transplantation in patients with non-
and multiple myeloma. This drug product is prescribedand sold in the United States using the trademark Mozobil
. Genzyme and Sanofi both share inthe profits from the sale of Mozobil
United States Patent No. RE42,152 (a true and accurate copy of which is attachedhereto as Exhibit A) was duly and legally issued on February 15, 2011 to inventors Gary J.