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Janssen Pharmaceuticals v. Haupt Pharma et. al.

Janssen Pharmaceuticals v. Haupt Pharma et. al.

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Published by PriorSmart
Official Complaint for Patent Infringement in Civil Action No. 2:12-cv-03034-SRC-MAS: Janssen Pharmaceuticals, Inc. v. Haupt Pharma, Inc. et. al. Filed in U.S. District Court for the District of New Jersey, the Hon. Stanley R. Chesler presiding. See http://news.priorsmart.com/-l69n for more info.
Official Complaint for Patent Infringement in Civil Action No. 2:12-cv-03034-SRC-MAS: Janssen Pharmaceuticals, Inc. v. Haupt Pharma, Inc. et. al. Filed in U.S. District Court for the District of New Jersey, the Hon. Stanley R. Chesler presiding. See http://news.priorsmart.com/-l69n for more info.

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Published by: PriorSmart on May 22, 2012
Copyright:Public Domain

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02/01/2013

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IN THE UNITED STATES DISTRICT COURTFOR THE DISTRICT OF NEW JERSEY
 JANSSEN PHARMACEUTICALS, )INC. ))Plaintiff, ))v. ) Civil Action No.)HAUPT PHARMA, INC., )RANBAXY LABORATORIES )LIMITED, and RANBAXY INC. ))Defendants. )
COMPLAINT FOR PATENT INFRINGEMENT
Plaintiff Janssen Pharmaceuticals, Inc., by its attorneys, for itscomplaint against Haupt Pharma, Inc. (“Haupt”), Ranbaxy LaboratoriesLimited (“Ranbaxy Laboratories”), and Ranbaxy Inc. (Ranbaxy Inc. andRanbaxy Laboratories, collectively “Ranbaxy”) (all three, collectively“Defendants”) alleges as follows:
The Parties
1.
 
Plaintiff is a corporation organized and existing under the lawsof Pennsylvania with its principal place of business at 1125 Trenton-Harbourton Road, Titusville, New Jersey 08560.
Case 2:33-av-00001 Document 14978 Filed 05/21/12 Page 1 of 9 PageID: 295051
 
 
- 2 -2.
 
Upon information and belief, Haupt is a corporation organizedunder the laws of Nevada with its principal place of business at 17471Highland Way Dr., Chesterfield, MO 63005-4257. Upon information andbelief, Defendant Haupt is a wholly-owned subsidiary of Haupt Pharma AG.3.
 
Upon information and belief, Haupt develops, sells, andmanufactures pharmaceutical products, including generic pharmaceuticalproducts.4.
 
Upon information and belief, Ranbaxy Inc. is a Delawarecorporation with its principal place of business at 600 College Road, Suite2100, Princeton, NJ 08540-6636.5.
 
Upon information and belief, Ranbaxy Inc. manufacturesnumerous generic drugs for sale and use throughout the United States,including in this judicial district, alone and/or through subsidiaries andagents.6.
 
Upon information and belief, Ranbaxy Laboratories is acompany organized and existing under the laws of India having its principalplace of business at Plot 90, Sector 32, Gurgaon - 122001 (Haryana), India.7.
 
Upon information and belief, Ranbaxy Laboratories is in thebusiness of developing, manufacturing, marketing, and sellingpharmaceutical products, including generic pharmaceutical products,
Case 2:33-av-00001 Document 14978 Filed 05/21/12 Page 2 of 9 PageID: 295052
 
 
- 3 -throughout the United States, including in this judicial district, through theactions of its agents and operating subsidiaries, including Ranbaxy Inc.8.
 
Upon information and belief, Ranbaxy Inc. is a wholly-ownedsubsidiary of Ranbaxy Laboratories.
Jurisdiction and Venue
9.
 
This is a civil action for patent infringement arising under thepatent laws of the United States, 35 U.S.C. § 271(e)(2) and 21 U.S.C. § 355.10.
 
This Court has jurisdiction over the subject matter of this actionpursuant to 28 U.S.C. §§ 1331 and 1338(a).11.
 
This Court has personal jurisdiction over Defendants by virtueof the fact that,
inter alia
, each Defendant has committed, or aided, abetted,contributed to and/or participated in the commission of, a tortious act of patent infringement that has led to foreseeable harm and injury to Plaintiff, acorporation having its principal place of business in New Jersey.12.
 
Haupt is also subject to personal jurisdiction in this judicialdistrict by virtue of,
inter alia
, having consented to personal jurisdiction forthis matter in this judicial district.13.
 
Ranbaxy Inc. is also subject to personal jurisdiction in this judicial district by virtue of,
inter alia
, its presence in New Jersey and itswidespread and continuous contacts with New Jersey.
Case 2:33-av-00001 Document 14978 Filed 05/21/12 Page 3 of 9 PageID: 295053

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