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Barry P. Golob

Member
P (202) 912-4815

Martin B. Pavane

Vice Chair, Intellectual Property Group
P (212) 883-4994

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      Hatch-Waxman Litigation

      The Hatch-Waxman Amendments to the Food, Drug & Cosmetic Act, which were passed in 1984, essentially established the current generic drug industry by allowing sponsors to demonstrate bioequivalence without having to conduct costly and time-consuming clinical trials.  With that market-entry barrier removed, real competition developed in a previously monopolistic marketplace.  Today, generic drugs represent sixty-nine percent of the total prescriptions dispensed in the United States but only sixteen percent of all dollars spent on prescription medications, saving American consumers nearly a trillion dollars over the last decade.

      From the generics’ perspective, the opportunity to provide life-saving, cost-effective medications was enhanced through Hatch-Waxman’s grant of 180-days of market exclusivity to the first applicant with a so-called Paragraph IV certification in an Abbreviated New Drug Application (“ANDA”).  Innovator companies were equally incentivized with an automatic 30-month stay of approval of the ANDA if they timely sued such an applicant upon receiving from the ANDA applicant the required notice of the Paragraph IV certification.  The United States is one of only a few markets in the world linking the regulatory approval of generic pharmaceutical products to its patent system.

      At first glance, navigating Hatch-Waxman’s patent certification and regulatory approval process may seem straightforward.  But one quickly learns there are many nuances and esoteric issues that require the expert guidance of counsel like Cozen O’Connor.   Our team has been lead litigation counsel in scores of Paragraph IV litigations, and we have counseled clients on scores more, each directed to a different generic product.  The vast majority of our cases have either been litigated to a successful conclusion or settled favorably for our generic clients.  One of our top compliments came from an adversary, the chief patent counsel for a well-known innovator company, who commented that our thorough settlement agreement addressed generic opportunities which the innovator had not even thought about.  Our publicly-available record of significant victories includes:

      ·  successfully defending the at-risk launch of generic Skelaxin® (metaxalone) with a favorable jury verdict finding the patent invalid and not infringed, with the innovator withdrawing its appeal after our appellate brief was filed;

      ·  obtaining appellate affirmance of judgment on the pleadings for the at-risk launch of generic Yasmin® (drospirenone + ethinyl estradiol);

      ·  resolving favorably at trial the at-risk launch of generic Neurtonin® (gabapentin) where the innovator was claiming several billion dollars in damages;

      · successfully litigating through appeal a challenge to our client’s launch of a generic version of Taxol® (paclitaxel);

      · successfully litigating through appeal a challenge to our client’s launch of a generic version of Zantac® (ranitidine);

      · successfully litigating through appeal a challenge to our client’s launch of Megace® (megestrol acetate);

      ·  defending our generic client at trial against two patents asserted against its at risk lauch of a generic version of Allegra® (fexofenadine), with the innovator dropping its case and covenanting not to sue our client before the court issued its decision;

      · favorably settling a challenge to our client’s launch of a generic version of Diprivan® (propofol) on the very night before trial, with launch proceeding as scheduled;

      · defending our generic client against a challenge to its launch of Vasotec® (enalapril), with the innovator dropping its case before trial and covenanting not to sue our client;

      ·  settling favorably other at-risk launches for the generic versions of Biaxin XL® (clarithromycin), Eloxatin® (oxaliplatin), Omnicef® (cefdinir), and Solodyn® (minocycline); and

      · securing affirmance of patent invalidity and unenforceability to allow a launch of generic Taxotere® (docetaxel).

       

      Our successful Hatch-Waxman practice extends beyond top-tier patent litigation.  To be successful, a generic sponsor also needs expert counsel on regulatory issues.  For example, while an ANDA product has to be the same as the reference product in certain respects (e.g., the active ingredient, strength, dosage form, and route of administration), a well-crafted filing strategy with a 505(b)(2) application that changes one or more of these elements may allow market entry more quickly and without being subject to a first applicant’s 180-days of exclusivity.  There may even be advantages in pursuing both a conventional ANDA and a 505(b)(2) application simultaneously. 

      Another regulatory area rife with opportunity is Orange Book patent use codes and data exclusivity descriptions, particularly with respect to what may (or may not) be “carved out” from a generic’s label.  A sophisticated approach includes a blend of patent certifications and carve-outs with a view to providing a new market opportunity and/or reducing patent litigation exposure.  Our publicly-available record concerning the regulatory facets of Hatch-Waxman includes citizen petitions arguing that:

      ·  select competitors should be required to submit new patent certifications relating to generic Actos® (pioglitazone) and Naropin® (ropivacaine), thereby causing the related thirty month stay to restart;

      ·  FDA should not permit certain label carve-outs for generic Lyrica® (pregabalin);

      ·  the first applicant’s 180-days of market exclusivity should be forfeited because the sponsor voluntarily adopted a packaging change from the reference listed product for generic Hectoral® (doxercalciferol);

      ·  the first applicant’s exclusivity for generic Nexium® (esomeprazole) should be forfeited for failure to obtain tentative approval in good time, even if missed by just by one day, an issue that was reported by The Wall Street Journal and other top news agencies.

       

      As a final example, our team was involved in successfully persuading FDA to overturn its grant of New Chemical Entity (“NCE”) exclusivity for Torisel® (temsirolimus) injection.  See Torisel Exclusivity Determination, Administrative and Correspondence Documents, Part 2, dated June 21, 2012, publicly available at Drugs@FDA.  The net result gave an ANDA applicant an opportunity for sole possession of the 180-day exclusivity rather than shared exclusivity among several NCE-1 ANDA applicants.  To our knowledge, this is the only instance where FDA has reversed itself as to a grant of NCE exclusivity in favor of a generic. 

      The generic market moves extremely fast and it is constantly changing.  Generic companies need top-tier counsel like Cozen O’Connor to help identify and pursue market opportunities without delay.  Two recent examples of change are: (1) the Inter Partes Review procedure established by the America Invents Act, which became effective on September 16, 2012, and (2) the impact on 180-day market exclusivity of The Food & Drug Administration Safety and Innovation Act (“FDASIA”), which was signed into law on July 9, 2012.

      Inter Partes Review offers the opportunity to significantly reduce litigation expenses by providing an alternative to conventional Hatch-Waxman litigation for challenging patent validity.  We have the experience and expertise to advise our clients as to whether and when to petition for such review.  As to the impact of FDASIA, depending on whether or not you are a first ANDA applicant, it may either extend the time permitted to obtain tentative approval to avoid forfeiting the 180-day exclusivity or create an opportunity for early market entry.  Either way, we can help.

      Hatch-Waxman litigation involves legal, regulatory, marketing, and scientific issues, and the Cozen O’Connor team is well-equipped to counsel you from product selection to launch and beyond.  Our attorneys hold advanced degrees in the natural sciences and nearly all members have experience as research scientists in industry or academia, meaning we understand the intersection of law and science. This is true not only for small molecules but also biosimilars and hybrid products in between, such as smaller polysaccharides and peptides.  We would welcome the opportunity for a detailed discussion of your particular needs.

      Experience

      Designed and implemented the litigation strategy as counsel for the second generic challenger in a patent infringement case involving patentee's drug, TAMBACOR©, a heart medication with sales exceeding $150 million. Summary judgment of noninfringement was obtained in less than six months after patentee filed its complaint in the U.S. District Court for the District of Minnesota. This judgment began tolling the 180-day exclusivity period of the first generic challenger, who was still facing trial and not yet on the market. The Federal Circuit subsequently affirmed the decision and, in doing so, expedited the client's market entry by many years. The Federal Circuit's decision resulted in a leading opinion on the proper application of the Hatch-Waxman Act, Minnesota Mining & Manufacturing Co. v. Barr Labs.


      Designed and implemented the litigation strategy as lead counsel for the declaratory-judgment plaintiff, a generic drug maker, in a patent infringement case involving Sanofi-Aventis’ drug RILUTEK©, before the Honorable Judge Farnan in the U.S. District Court for the District of Delaware. A preemptory declaratory judgment attack precluded patentee from relying on the statutory 30-month stay on approval, resulting in approval of the generic alternative only six months after the ANDA was filed. Impax Labs., Inc. v. Aventis Pharmaceuticals, Inc.


      Represented Wockhardt in ANDA litigation regarding LUNESTA®, the active ingredient of which is eszopiclone. Settled prior to trial on terms the client found favorable.


      Represented Signalization VerMac in declaratory judgment patent infringement action relating to solar tilt and rotate features of roadside message boards. Settled the case on terms the client found favorable after discovery.


      Patent infringement action regarding Apotex's ANDA to make a generic version of Sanofi-Aventis' anti-cancer product TAXOTERE®, the active ingredient of which is docetaxel. Following a two-week trial, obtained an order for Apotex striking down the patents-in-issue as invalid and unenforceable due to Sanofi-Adventis' inequitable conduct in procuring the patents.


      Represented Lockheed Martin Corp. in opposing an effort by Zoltek Corp. to substitute it as a defendant in a patent-infringement action Zoltek had originally brought against the United States stemming from the U.S.'s alleged use of Zoltek's patent in the manufacture of the F-22 fighter plane. Obtained a decision from the U.S. Court of Appeal for the Federal Circuit allowing it to seek an interlocutory appeal of a Court of Federal Claim's decision that Lockheed was not protected by government-contractor immunity pursuant to 28 U.S.C. §1498. Subsequent en banc Federal Circuit reversed trial court ruling thereby dismissing Lockheed Martin as a party.


      Represented our client, Sandoz Inc., in a patent infringement action regarding Sandoz's ANDA to make a generic version of Medicis' acne product SOLODYN® (minocycline hydrochloride).


      Lead counsel for Sandoz Inc., in a patent infringement action regarding Sandoz's ANDA to make a generic version of Endo's pain product OPANA® ER (oxymorphone hydrochloride).


      Represented Apotex Inc., in a patent infringement action regarding Apotex's ANDA to make a generic version of Wyeth's anti-depressant product EFFEXOR XR® (venlafaxine hydrochloride). Settled on favorable terms during trial.


      Represented Apotex Inc., in a patent infringement action regarding Apotex's ANDA to make a generic version of Sanofi-Aventis' anticancer product TAXOTERE®, the active ingredient of which is docetaxel. Following a two-week trial, obtained an order for Apotex striking down the patents-in-issue as invalid as obvious and unenforceable due to Sanofi-Aventis' inequitable conduct in procuring the patents. Successfully argued on appeal with the Federal Circuit affirming trial court decision (April 2012). Of import is that inequitable conduct defense remains viable in ANDA litigations because of this ruling.


      Handled a patent infringement action regarding Apotex's ANDA to make a generic version of Pfizer's migraine product Relpax®, the active ingredient of which is eletriptan hydrobromide.


      Represented Sandoz Inc. in a patent infringement action regarding Eon/Sandoz's abbreviated new drug application (ANDA) to make a generic version of Pfizer’s anti-seizure product Neurontin®, the active ingredient of which is gabapentin.


      Handled a patent infringement action regarding Schwarz Pharma’s ANDA to make a generic version of Braintree Labs’ constipation product Miralax®, the active ingredient of which is polyethylene glycol. During discovery, Braintree dismissed its infringement complaint, waiving the remaining portion of the 30 month stay on FDA approval of Schwarz Pharma’s product.


      Represented our client, Sandoz Inc., in a patent infringement action regarding Sandoz's ANDA to make a generic version of Allergan's glaucoma drops COMBIGAN® (brimonidine tartrate/timolol maleate.)


      Represented Sandoz Inc., in a patent infringement action regarding Sandoz's ANDA to make a generic version of Merck's anti-nausea product EMEND® (aprepitant).


      Designed and implemented the litigation strategy as lead counsel for defendant, a Taiwanese semiconductor manufacturer, in a patent infringement case involving DC/AC power inverters for LCD panels in portable electronic devices. The defense resulted in a judgment as a matter of law on the issues of direct and contributory infringement and plaintiff's abandonment of a $120 million-plus damage claim (jury finding of inducement was reversed on appeal).


      Represented Chimei InnoLux Corporation, f/k/a InnoLux Display Corporation, in a patent infringement case involving brightness-enhancing films used in LCD devices. Plaintiff dismissed its case against our client, with prejudice, after the special master indicated he would recommend granting defendant's motion for summary judgment.


      Represented our client in a patent infringement action regarding Actavis' ANDA to make a generic version of King's pain product AVINZA®, the active ingredient of which is morphine sulfate.


      Represented our client, Mylan Pharmaceuticals, Inc., in a patent infringement action regarding Mylan's ANDA to make a generic version of Pfizer's cardiovascular product CADUET®, the active ingredients of which are atorvastatin calcium and amlodipine besylate. Settled prior to trial.


      Represented Apotex Inc., in a patent infringement action regarding Apotex's ANDA to make a generic version of Procter's osteoporosis product ACTONEL® (risedronate).


      Represented our client, Sandoz Inc., in a patent infringement action regarding Sandoz's ANDA to make a generic version of Abbott’s ZEMPLAR® (paricalcitol).


      Represented Apotex Inc., in a patent infringement action regarding Apotex’s ANDA to make a generic version of LYSTEDA (tranexamic acid). Matter pending.


      Represented Apotex Inc., in a patent infringement action regarding Apotex’s ANDA to make a generic version of ACULAR LS® (0.4% ketorolac tromethamine). Matter pending.


      Represented Apotex Inc., in a patent infringement action regarding Apotex’s ANDA to make a generic version of PRISTIQ® (desvenlafaxine). Matter pending.


      Represented Sandoz Inc., in a patent infringement action regarding Sandoz's ANDA to make a generic version of Shire’s ADHD product INTUNIV® (guanfacine hydrochloride). Matter pending.


      Represented Sandoz Inc., in a patent infringement action regarding Sandoz’s ANDA to make a generic version of Roche’s VALCYTE® (valganciclovir hydrochloride). Matter pending.


      Represented our client, Sandoz Inc., in patent infringement action regarding Sandoz’s ANDA to make a generic version of Helsinn’s anti-nausea product ALOXI® (palonosetron hydrochloride injection). Matter pending.


      Represented our client in a patent infringement action regarding InnoPharma’s ANDA to make a generic version of Spectrum’s FUSILEV® (levoleucovorin). Matter pending.


      Represented our client, Sandoz Inc., in a patent infringement action regarding Sandoz’s ANDA to make a generic version of Abbott’s cholesterol medication TRILIPIX® (fenofibric acid). Matter pending.


      Represented our client, Sandoz Inc., in a patent infringement action regarding Sandoz’s ANDA to make a generic version of Abbott’s cholesterol product NIASPAN® (niacin). Matter pending.


      Represented our client, Sandoz Inc., in a patent infringement action regarding Sandoz's ANDA to make a generic version of Alcon's eye allergy product PATANOL® (olopatadine hydrochloride).


      Represented client CardSoft in patent infringement action against multiple defendants who manufactured and sold infringing electronic point-of-sale ("ePOS") terminals using “swipe-technology.” Successfully secured patent damages for client in excess of $15 million for CardSoft in jury trial against VeriFone Systems, Inc. and VeriFone, Inc. (VeriFone) and Hypercom Corp. (Hypercom).


      Lead counsel in damage phase of a patent infringement action regarding Sandoz's ANDA to make a generic version of Pfizer’s seizure and neuropathic pain product, Neurontin®, the active ingredient of which is gabapentin.


      Handled a patent infringement action regarding Sandoz's ANDA to make a generic version of Pfizer’s antifungal medication VFEND®, the active ingredient of which is voriconazole.


      Handled a patent infringement action regarding Sandoz's ANDA to make a generic version of Pfizer’s antimuscarinic tablet Detrol and Detrol LA®, the active ingredient of which is tolterodine tartrate.


      Handled a patent infringement action regarding Sandoz's ANDA to make a generic version of Alcon's eye allergy product Pataday®, the active ingredient of which is olopatadine hydrochloride.


      Represented our client in a patent infringement action regarding Apotex’s ANDA to make a generic version of AVODART® (dutasteride). Matter pending.


      Attorneys

      Joseph M. Bennett-Paris, Ph.D. Member Atlanta (404) 572-2024
      J. Trevor Cloak Associate Philadelphia (215) 665-4702
      W. Blake Coblentz Member Washington, D.C. (202) 912-4837
      Tia C. Ghattas Office Managing Partner Chicago (312) 382-3116
      Barry P. Golob Member Washington, D.C. (202) 912-4815
      Julia S. Kim Member New York (212) 883-4998
      Philip Y. Kouyoumdjian Member New York (212) 883-4900
      Aaron Lukas Associate Washington, D.C. (202) 912-4823
      Donald Robert McPhail Member Washington, D.C. (202) 912-4819
      Kerry B. McTigue Co-Chair, Intellectual Property Group Washington, D.C. (202) 912-4810
      Camille M. Miller Co-Chair, Intellectual Property Group Philadelphia (215) 665-7273
      Darren S. Mogil Associate New York (212) 883-4976
      Alan J. Morrison Member New York (212) 297-2696
      Marilyn Neiman Member New York (212) 883-4985
      Martin B. Pavane Vice Chair, Intellectual Property Group New York (212) 883-4994
      Richard T. Ruzich Chair, ANDA & Biologics Practice Group Chicago (312) 382-3105
      Ian Scott Member New York (212) 908-1205
      Kyle Vos Strache Associate Philadelphia (215) 665-2747

      Publications


      Health-Care Reform Creates Large-Dollar Biosimilar Drug Market [Chicago Daily Law Bulletin]

      November 08, 2012

      MORE

      Events & Seminars

      American Conference Institute Paragraph IV Disputes New York, NY 05/07/2013
      Columbia University Bioethics Course New York, NY 04/24/2013
      2013 BIO International Convention Chicago, IL 04/22/2013
      Through the Looking Glass – Fine-tune Fundamentals of Hatch-Waxman and Anticipate Future Developments in Patent Litigation Washington, DC 10/25/2012
      A Closer Look at Generic v. Generic Law Suits New York, NY 04/27/2010

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