pharmaceutical products, including Levaquin (levofloxacin, an antibiotic) and Ultram (tramadol,
a pain reliever) in this District and nationwide. Ortho McNeil also manufactures tramadol in
combination with acetaminophen - this combination is marketed as Ultracet. The Ortho McNeil
tramadol kickbacks-for-switches scheme involved both Ultram and Ultracet, and the term
"Ultram/Ultracet" will refer to both drugs collectively.
Defendant Janssen, LP ("Janssen") is a New Jersey limited partnership with a
principal place of business in Titusville, NJ, within 100 miles of Philadelphia, PA. Janssen is a
collectively referred to as "Janssen." Janssen sells its pharmaceutical products, including
Risperdal (risperidone, an atypical antipsychotic) in this District and nationwide.
JURISDICTION AND VENUE
This Court has jurisdiction over the subject matter of this civil action, arising
under the laws of the United States, pursuant to: (i) 31 U.S.C. §3732, which specifically confers
jurisdiction on this Court for actions brought pursuant to 31 U.S.C. §§3729 and 3730; (ii) 28
U.S.c. §1331, which confers federal subject matter jurisdiction; and (iii) 28 U.S.c. §1345,
because the United States is a plaintiff.
Jurisdiction over all state law claims alleged herein is proper under 31 U.S.c.
§3732(b). This Court has supplemental jurisdiction over all state law claims under 28 U.S.C.
Manufacturers Bristol Myers, Pfizer, Ortho McNeil, J&J, and Janssen, because they can be found
in, are authorized to transact business in, and are now transacting business in this District. This