In Re Tamoxifen Citrate Antitrust Litigation
Plaintiffs Caroline Marks, Maxine Blonstein, and Lois Steward, representing classes of consumers and indirect purchasers of tamoxifen citrate in California, Florida, and Kansas, respectively, originally filed state antitrust and consumer protection claims against defendants Zeneca, Inc., AstraZeneca Pharmaceuticals LP, AstraZeneca LP, AstraZeneca PLC (collectively “Zeneca”) and Barr Laboratories, Inc. (“Barr”). The cases were removed to federal court, and plaintiffs now seek to remand them, arguing a lack of subject matter jurisdiction. Defendants argue for federal question jurisdiction under federal patent law, the Noerr-Pennington Doctrine, and collateral attack on federal court orders, as well as diversity jurisdiction for the Marks class action. The Court, applying Second Circuit law, concludes that the plaintiffs' claims necessarily depend on the resolution of a substantial question of federal patent law, thus establishing federal question jurisdiction. Therefore, the motions to remand are denied, and the cases remain in federal court.