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inhibitors") designed to lower high blood pressure. Abilify (aripiprazole) is a member of a class

of drugs known as atypical antipsychotics, used to treat schizophrenia and other serious mental

health problems. Bristol Myers manufactures, markets, and distributes Abilify in conjunction

with its discoverer, Japanese pharmaceutical concern Otsuka Pharmaceuticals, Inc.

23.

Defendant Pfizer, Inc. ("Ptizer") is a Delaware corporation with a manufacturing

facility

in

Lititz,

PA,

in

Lancaster

County

in

this

District.

ptizer

sells

its

pharmaceutical

products, including Lipitor (atorvastatin calcium, a "statin" medication designed to lower

cholesterol) and Accupril (quinapril, an ACE inhibitor), in this District and nationwide.

24.

Defendant Pfizer entered into a Corporate Integrity Agreement ("CIA") with the

United States Department of Justice as part of a settlement in a case involving alleged False

Claims Act liability concerning Pfizer's sale and distribution of Neurontin, an antiseizure

medication. As part of this CIA, ptizer's officers agreed that the company would maintain an

enhanced ethical and legal posture with respect to government-funded health care programs.

Pfizer also promised to certify on a regular basis that it has maintained compliance with the CIA.

Pfizer's conspiracy with Omnicare is in direct violation of the terms of this Corporate Integrity

Agreement.

25.

Defendant Johnson & Johnson ("J&J") is a New Jersey corporation with its

principal place of business in New Brunswick, NJ, within 100 miles of Philadelphia, PA.

J&J

sells its pharmaceutical products in this District and nationwide.

26.

Defendant Ortho McNeil Pharmaceuticals, Inc. ("Ortho McNeil") is a Delaware

corporation with a manufacturing facility in Spring House, PA, in Montgomery County in this

District. Ortho McNeil is a wholly-owned subsidiary of J&J. In this Complaint, therefore, J&J

and Ortho McNeil will be collectively referred to as "Ortho McNeil." Ortho McNeil sells its

7

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