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indirectly, to officers, employees, or agents of the United States, for Monopril, Abilify, and other

drugs.

266.

By virtue of the above-described acts, among others, Pfizer knowingly caused to

be presented false or fraudulent claims for payment or approval, and possibly continues to cause

to be submitted false or fraudulent claims for payment or approval, directly or indirectly, to

officers, employees, or agents of the United States, for Lipitor, Accupril, and other drugs.

267.

Defendant Manufacturers knowingly and

intentionally conspired to,

and caused

false claims for payment to be submitted for prescription drugs from the implementation of each

individual scheme to date in violation of the Illinois Insurance Claims Fraud Prevention Act.

The earliest scheme was the Monopril switching in 1998, and the scheme continued with

subsequent rollouts every few months.

268.

By virtue of the above-described acts,

among others,

011ho McNeil knowingly

caused to be presented false or fraudulent claims for payment or approval, and possibly

continues to cause to be submitted false or fraudulent claims for payment or approval, directly or

indirectly, to officers, employees, or agents of the United States, for Levaquin, Ultram/Ultracet,

and other drugs.

269.

The amounts of the false or fraudulent claims to the United States were material.

270.

Plaintiff United States, being unaware of the falsity of the claims caused to be

made by the Defendant Manufacturers, and in reliance on the accuracy thereof paid and may

continue

to

pay

for

the

Defendant

Manufacturers'

"preferred"

drugs.

All

unlawful

conduct

described above may have continued after Lisitza's termination with Omnicare.

271.

From 1998 to the date of this Complaint, by reason of the conduct described

above, the government has been damaged in an amount that is believed to be in excess of $3.5

71

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