Novo Nordisk of North America, Inc. v. Genentech, Inc.
The plaintiffs, three Novo Nordisk entities, sued defendant Genentech seeking a declaratory judgment of patent invalidity and non-infringement, and asserted antitrust claims. Genentech filed a motion to dismiss claims three and four of the plaintiffs' complaint. The court granted in part Genentech's motion, dismissing the 'sham' litigation antitrust claim (claim four) under the Noerr-Pennington doctrine, finding the prior ITC proceeding was not objectively baseless. However, the court denied dismissal of the 'Walker Process' antitrust claim (claim three), which alleged fraudulent procurement of a patent, due to uncertainty regarding Noerr-Pennington's applicability to such claims and adequate pleading of a Sherman Act violation. The motion to dismiss was partially granted, dismissing the 'sham' litigation claim but allowing the 'fraudulent procurement' claim to proceed.