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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.

27.

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

wholly-owned

subsidiary

of

J&J.

In

this

Complaint,

therefore,

J&J

and

Janssen

will

be

collectively referred to as "Janssen." Janssen sells its pharmaceutical products, including

Risperdal (risperidone, an atypical antipsychotic) in this District and nationwide.

  • III.

    JURISDICTION AND VENUE

    • 28.

      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.

29.

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.

§1367.

30.

This

Court

has

jurisdiction

under

31

U.S.C.

§3732(a)

over

Defendant

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

8

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