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schemes similar to the one effected with Omnicare. The specific circumstances alleged herein

evidence a pattern of conduct by Janssen designed to maximize profits through this scheme at

every opportunity, through various other drugs and other providers.

J.

DEFENDANT MANUFACTURER ORTHO McNEIL AND OMNICARE ENTER INTO A MARKET SHARE AGREEMENT WITH RESPECT TO ULTRAMiULTRACET

162.

Defendant Manufacturer Ortho McNeil

entered into a Market Share Agreement

with Omnicare with respect to its pain medication Ultram/Ultracet (tramadol). Competing drugs

include Tylenol #3, Tylenol #4, Darvocet, and vicodin. Ortho McNeil and Omnicare conspired

to switch many pain medication prescriptions for Omnicare-serviced patients to Ultram/Ultracet.

163.

Ortho

McNeil

executives

at

the

time

period

of

the

development

and

implementation of the Ultram/Ultracet scheme included but were not limited to, John H.

Johnson, Bob Spurr, Nawaz Merchant, Eneetra P. Livings, Paul Kim, Tom Petro, and Marty

Murray.

164.

Because

Ortho

McNeil

is

a

wholly-owned

subsidiaries

of

J&J,

all

activities

alleged with respect to Ortho McNeil are also alleged with respect to J&J.

165.

Ortho McNeil representatives often visited Omnicare locations for the purpose of

promoting the switches. Ortho McNeil 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 Tylenol #3, Tylenol

#4, Darvocet, and vicodin to UltramlUltracet.

166.

Ortho

McNeil

marketing

personnel

met

with

Omnicare

pharmacists

before

the

commencement of mass switching to Ultram/Ultracet to educate pharmacists on how to make the

switches.

Meetings

were

held

with

Omnicare

staff

where

Ortho

McNeil's

marketing

staff

informed Omnicare's front line pharmacists and pharmacy supervisors that the switches were not

45

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