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.
Defendant Pfizer, Inc. ("Ptizer") is a Delaware corporation with a manufacturing
products, including Lipitor (atorvastatin calcium, a "statin" medication designed to lower
cholesterol) and Accupril (quinapril, an ACE inhibitor), in this District and nationwide.
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
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.
sells its pharmaceutical products in this District and nationwide.
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