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119.

Pfizer

representatives

often

visited

Omnicare

locations

for

the

purpose

of

promoting

the

switches.

Pfizer

developed

special

materials

targeted

solely

to

Omnicare

pharmacists and physicians in Omnicare-serviced nursing homes to "educate" these audiences on

the importance of the switching program and on how to switch patients from other ACE

inhibitors (including, by this time, mostly Monopril) to Accupril.

120.

Pfizer's

marketing

personnel

met

with

Omnicare

pharmacists

before

the

commencement of mass switching to Accupril to educate pharmacists on how to make the

switches. Meetings were held with Omnicare staff where Pfizer's marketing staff and Omnicare

senior management together informed Omnicare's front line pharmacists and pharmacy

supervisors that the switches were not only going to be beneficial to patients in Omnicare-

serviced long-term care facilities, but would save payors money.

121.

Pfizer also made marketing agents available to Omnicare pharmacists who needed

subsequent technical assistance to switch patients from other ACE inhibitors to Accupril.

122.

Pfizer

also

worked

with

Omnicare

to

illegally

solicit

PALs

from

physicians

authorizing blanket switches to Accupril.

Pfizer's actions in furtherance of this conspiracy

included:

  • Making false statements 10 Omnicare fi'onl line pharmacy personnel as to the reason for the switching. Pfizer made false representations to Omnicare pharmacy staft: through materials prepared uniquely for Omnicare staff, through "kickoff' and other meetings designed to maximize the wholesale switching, and through making themselves available for technical consultations. These false representations included:

    • o

      That the switch to Accupril was financially advantageous to the government and private insurers, when this was almost never the case.

  • o

    That Accupril was clinically the most appropriate ACE inhibitor, when frequently

this, too, was not the case.

  • Making false statements to physicians as to the reasons for the switching. Pfizer made its

marketing personnel available at Omnicare-serviced nursing homes to work with

33

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