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`
`
`United States Court of Appeals
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`for the
`Third Circuit
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`Case No. 24-
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`
`
`IN RE INSULIN PRICING LITIGATION
`
`_____________________________
`
`ON PETITION FOR PERMISSION TO APPEAL FROM THE UNITED STATES
`DISTRICT COURT FOR THE DISTRICT OF NEW JERSEY IN
`CASE NO. 2:17-CV-00699, HONORABLE BRIAN R. MARTINOTTI
`
`PETITION FOR PERMISSION TO APPEAL PURSUANT
`TO FED. R. CIV. P. 23(F) AND FED. R. APP. P. 5
`AND APPENDIX
`Volume 1 of 2 (Pages A1 to A123)
`
`
`
`STEVE W. BERMAN
`CRAIG R. SPIEGEL
`HAGENS BERMAN SOBOL
`SHAPIRO LLP
`1301 Second Avenue, Suite 2000
`Seattle, Washington 98101
`(206) 623-7292
`
`THOMAS M. SOBOL
`HANNAH W. BRENNAN
`HAGENS BERMAN SOBOL
`SHAPIRO LLP
`55 Cambridge Parkway, Suite 301
`Cambridge, Massachusetts 02142
`(617) 482-3700
`
`JAMES E. CECCHI
`DONALD A. ECKLUND
`JAMES A. O’BRIEN III
`CARELLA, BYRNE, CECCHI, BRODY
`& AGNELLO, P.C.
`Five Becker Farm Road
`Roseland, New Jersey 07068
`(973) 994-1700
`
`MARK T. VAZQUEZ
`HAGENS BERMAN SOBOL
`SHAPIRO LLP
`455 North Cityfront Plaza Drive,
`Suite 2410
`Chicago, Illinois 60611
`(708) 628-4949
`
`Attorneys for Plaintiffs and Interim Co-Lead Counsel for the Class
`
`(800) 4-APPEAL • (327358)
`
`
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`Case: 24-8002 Document: 1-1 Page: 2 Date Filed: 02/07/2024
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`TABLE OF CONTENTS
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`Page
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`INTRODUCTION ........................................................................................ 1
`
`
`
`
`I.
`
`II. QUESTIONS PRESENTED ..................................................................... 5
`
`III. ARGUMENT ................................................................................................. 7
`
`A.
`
`B.
`
`The Rule 23(f) petition should be granted because
`the district court violated Hydrogen Peroxide when
`it failed to weigh competing expert testimony. .......................... 8
`
`The Rule 23(f) petition should be granted because
`the district court incorrectly ruled that, under state
`consumer protection law, each diabetic patient needs
`to explain why she could not have avoided or otherwise
`offset the defendants’ misconduct. .............................................. 14
`
`1.
`
`2.
`
`The district court erred—as a matter of
`law—by requiring class members to individually
`demonstrate that they could not have avoided or
`otherwise offset the effect of the defendants’
`unconscionable and unfair prices. .................................... 14
`
`The district court erred—as a matter of
`law—in finding preclusive variations between
`the state laws at issue. ........................................................ 20
`
`C.
`
`The Rule 23(f) petition should be granted because the
`district court incorrectly concluded the class members
`had not sustained an “ascertainable loss.” ................................ 23
`
`1.
`
`For an unconscionability violation of the
`NJCFA, an individual does not need to be
`“misled” to suffer an “ascertainable loss.” ...................... 23
`
`
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`i
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`Case: 24-8002 Document: 1-1 Page: 3 Date Filed: 02/07/2024
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`2.
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`The district court misunderstood the plaintiffs’
`claims as pursuing a “fraud-on-the-market” or
`“price inflation” theory. ....................................................... 26
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`IV. CONCLUSION ........................................................................................... 29
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`CERTIFICATE OF COMPLIANCE ................................................................ 30
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`ii
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`Case: 24-8002 Document: 1-1 Page: 4 Date Filed: 02/07/2024
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`TABLE OF AUTHORITIES
`
`CASES
`
` Page(s)
`
`Albaugh v. The Reserve,
`930 N.W.2d 676 (Iowa 2019) ................................................................ 22
`
`Amgen Inc. v. Connecticut Ret. Plans & Tr. Funds,
`568 U.S. 455 (2013) ...................................................................... 4, 6, 15
`
`In the Matter of Apple Inc.,
`2014 WL 1330287 (FTC Mar. 25, 2014) .............................................. 15
`
`Arch Ins. Co. v. Precision Stone, Inc.,
`584 F.3d 33 (2d Cir. 2009) ................................................................... 19
`
`Atl. City Elec. Co. v. Gen. Elec. Co.,
`226 F. Supp. 59 (S.D.N.Y. 1964) .......................................................... 18
`
`Bosland v. Warnock Dodge, Inc.,
`197 N.J. 543 (2009) ........................................................................ 24, 25
`
`Cheramie Servs. v. Shell Deepwater Prod.,
`35 So. 3d 1053 (La. 2010) ..................................................................... 22
`
`In re Cmty. Bank of N. Va. Mortg. Lending Pracs. Litig.,
`795 F.3d 380 (3d Cir. 2015) ................................................................. 16
`
`D’Agostino v. Maldonado,
`216 N.J. 168 (2013) .............................................................................. 24
`
`In re EpiPen Litig.,
`2020 WL 1180550 (D. Kan. Mar. 10, 2020) ........................................ 20
`
`Forst v. Live Nation Ent. Inc.,
`2015 WL 858314 (D.N.J. Feb. 27, 2015) ............................................. 25
`
`
`
`iii
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`Case: 24-8002 Document: 1-1 Page: 5 Date Filed: 02/07/2024
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`FTC v. Amazon.com, Inc.,
`2016 WL 10654030 (W.D. Wash. July 22, 2016) ................................ 15
`
`FTC v. Direct Benefits Grp., LLC,
`2013 WL 3771322 (M.D. Fla. July 18, 2013) ...................................... 16
`
`FTC v. Elec. Payment Sols. of Am. Inc.,
`482 F. Supp. 3d 921 (D. Ariz. 2020) .................................................... 15
`
`FTC v. Neovi, Inc.,
`604 F.3d 1150 (9th Cir. 2010) .............................................................. 15
`
`Hanover Shoe, Inc. v. United Shoe Mach. Corp.,
`392 U.S. 481 (1968) .............................................................................. 18
`
`Harnish v. Widener Univ. Sch. of L.,
`833 F.3d 298 (3d Cir. 2016) ..................................................... 25, 26, 27
`
`Hawaii v. Standard Oil Co. of Cal.,
`405 U.S. 251 (1972) .......................................................................... 6, 17
`
`In re Hydrogen Peroxide Antitrust Litig.,
`552 F.3d 305 (3d Cir. 2008), as amended (Jan. 16, 2009) ........ 3, 5, 6, 8
`
`Kalow & Springut, LLP v. Commence Corp.,
`2012 WL 6093876 (D.N.J. Dec. 7, 2012) ............................................. 15
`
`Laudato v. EQT Corp.,
`23 F.4th 256 (3d Cir. 2022) ............................................................ 5, 7, 8
`
`In re Lidoderm Antitrust Litig.,
`2017 WL 679367 (N.D. Cal. Feb. 21, 2017) ......................................... 17
`
`Luskin’s, Inc. v. Consumer Prot. Div.,
`726 A.2d 702 (Md. 1999) ...................................................................... 23
`
`MacDonald v. Cashcall, Inc.,
`333 F.R.D. 331 (D.N.J. 2019) ............................................................... 25
`
`
`
`iv
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`Case: 24-8002 Document: 1-1 Page: 6 Date Filed: 02/07/2024
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`In re Nexium Antitrust Litig.,
`777 F.3d 9 (1st Cir. 2015) .................................................................... 17
`
`In Re Pharm. Indus.Average Wholesale Price Litig.,
`582 F.3d 156 (1st Cir. 2009) .................................................................. 2
`
`Pollard v. AEG Live, LLC,
`2014 WL 4637017 (D.N.J. Sept. 16, 2014) .......................................... 28
`
`Smajlaj v. Campbell Soup Co.,
`782 F. Supp. 2d 84 (D.N.J. 2011) .................................................. 25, 26
`
`In re Solodyn (Minocycline Hydrochloride) Antitrust Litig.,
`2017 WL 4621777 (D. Mass. Oct. 16, 2017) ........................................ 17
`
`Southern Pac. Co. v. Darnell-Taenzer Lumber Co.,
`245 U.S. 531 (1918) ........................................................................ 18, 19
`
`Sullivan v. DB Invs., Inc.,
`667 F.3d 273 (3d Cir. 2011) ....................................................... 4, 15, 20
`
`In re Syngenta AG MIR 162 Corn Litig.,
`2016 WL 5371856 (D. Kan. Sept. 26, 2016) ........................................ 19
`
`In re Thalomid & Revlimid Antitrust Litig.,
`2018 WL 6573118 (D.N.J. Oct. 30, 2018) ............................................ 17
`
`In re Valsartan, Losartan, & Irbesartan Prod. Liab. Litig.,
`2023 WL 1818922 (D.N.J. Feb. 8, 2023) ............................................. 21
`
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`v
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`Case: 24-8002 Document: 1-1 Page: 7 Date Filed: 02/07/2024
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`I.
`
`INTRODUCTION
`
`People living with diabetes ask this Court to review a district
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`court’s decision to effectively terminate the claims of several million
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`diabetics harmed by the defendants’ insulin price manipulation. Eli
`
`Lilly, Novo Nordisk, and Sanofi know that the list prices they set will be
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`mechanistically used to calculate the point-of-sale costs to insulin
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`consumers.1 Nevertheless, they posted exorbitant list prices for
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`consumers that bore no relation to the net prices insurers pay. As a
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`result, diabetic patients make payments for insulin that far exceed the
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`true market price. To right this wrong, patients brought class claims
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`under state consumer protection laws that prohibit unfair and
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`unconscionable conduct. Through serious misinterpretation of this
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`1 Insulin manufacturers publish for each insulin product a single
`“list” price (either wholesale acquisition cost, WAC, and/or average
`wholesale price, AWP) used nationwide. For insured patients, when the
`drug is dispensed at the pharmacy (the point-of-sale), contracts with the
`pharmacy, health plan, and benefits manager all use the published
`“list” price as an input to calculate the total amount charged, including
`the patient percentage cost-share or deductible amount. For uninsured
`patients, the pharmacy uses the same published “list” price to calculate
`the usual and customary (U&C) charge. Thus, when “list” prices
`increase, so do the cash or cost-share charges to the patient. Class Cert.
`Br. at 18-24 (Dkt.# 575).
`
`
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`1
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`Case: 24-8002 Document: 1-1 Page: 8 Date Filed: 02/07/2024
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`Court’s and the states’ laws, the district court denied class certification
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`in one of the country’s most important public health matters.
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`Since this case was filed, insulin prices have elicited universal
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`condemnation. Two presidential administrations and two bipartisan
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`Congressional commissions have denounced defendants’ gouging of
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`insulin users. Even the defendants have acknowledged their bloated list
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`prices used for point-of-sale transactions—while later kicking back huge
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`off-invoice rebates to insurers—forced patients to overpay.
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`No case presents a more heartland opportunity to use state
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`consumer protection laws and Rule 23 to compensate for unconscionable
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`acts. Indeed, years ago, similar drug list price abuse led to numerous
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`class certifications, settlements, and a trial under states laws in In Re
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`Pharmaceutical Industry Average Wholesale Price Litigation.2 This
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`action allowed millions of patients to recover for analogous overcharges
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`on scores of drugs. Yet, here, the court’s denial of class certification
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`2 582 F.3d 156 (1st Cir. 2009).
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`
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`2
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`Case: 24-8002 Document: 1-1 Page: 9 Date Filed: 02/07/2024
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`threatens the unconscionability claims of millions of patients. Plaintiffs
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`ask this Court to grant Rule 23(f) review to cure the following mistakes.
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`First, the district court ignored Hydrogen Peroxide’s directive that
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`Rule 23’s “rigorous analysis” requires the district court to evaluate the
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`evidence on both sides of the case.3 In its predominance analysis, the
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`district court adopted the unsupported opinions of Dr. Baker
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`(defendants’ expert), without addressing even one counterpoint of Dr.
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`Rosenthal (plaintiffs’ expert). The court not only misapplied Hydrogen
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`Peroxide but inverted it, ignoring all of plaintiffs’ expert testimony and
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`crediting as a matter-of-fact defendants’ expert. This divergence from
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`Hydrogen Peroxide cannot stand.
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`Second, the district court erred by denying certification based on
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`hypothetical actions the defendants claim diabetics should have taken
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`to avoid defendants’ prices. The district court blamed the victims,
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`requiring patients to explain why they had not sought charity, sussed
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`out coupons, obtained insurance (or better insurance or even a new job
`
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`3 In re Hydrogen Peroxide Antitrust Litig., 552 F.3d 305, 323-25 (3d
`Cir. 2008), as amended (Jan. 16, 2009).
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`
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`3
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`Case: 24-8002 Document: 1-1 Page: 10 Date Filed: 02/07/2024
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`to access a different plan). The Supreme Court and this Circuit direct
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`that the Rule 23(b)(3) analysis focus on whether defendants’ conduct
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`was common to all class members, not whether each plaintiff has a
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`colorable claim on the merits.4 Courts across the country uniformly hold
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`that merely speculating about the possibility of impractical and
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`unreasonable mitigation measures does not bar recovery for unfair and
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`unconscionable practices.5 The district court’s ruling on this score also
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`violates long-standing Supreme Court precedent clarifying that injury
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`occurs at purchase and potential downstream offsets are irrelevant as a
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`matter of law.
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`Third, the district court erred in ruling that the class has not
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`suffered an ascertainable loss under the New Jersey Consumer Fraud
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`Act (NJCFA). An ascertainable loss is one that is “quantifiable.” But
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`simple math demonstrates plaintiffs’ overpayment. The district court
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`confused this case—one where the defendants directly impose a real
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`4 See Amgen Inc. v. Connecticut Ret. Plans & Tr. Funds, 568 U.S.
`455, 459 (2013); Sullivan v. DB Invs., Inc., 667 F.3d 273, 299 (3d Cir.
`2011).
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`5 See infra n.33.
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`
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`4
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`Case: 24-8002 Document: 1-1 Page: 11 Date Filed: 02/07/2024
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`overcharge—with fraud-on-the-market cases—where the defendant’s
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`actions generally affect a hypothetical market price. This mistake led
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`the district court to believe plaintiffs lacked a remedy under the NJCFA
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`and must be cured.
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`This is a textbook case of why Rule 23(f) was adopted. It meets all
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`this Circuit’s standards for granting review: (1) the decision effectively
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`terminates one of the most important public health and public interest
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`cases in the country, (2) violates this Court’s directive in Hydrogen
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`Peroxide, and (3) will facilitate clarification of the application of unfair
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`and unconscionable practices law in class actions.6 This Court should
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`exercise its “very broad discretion” in “using a more liberal standard”
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`for 23(f) petitions and grant this petition.7
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`II. QUESTIONS PRESENTED
`
`1.
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`In Hydrogen Peroxide, this Court ruled that where parties
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`present competing expert evidence on questions relevant to the Rule 23
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`analysis, district courts must consider and weigh both experts’
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`6 Laudato v. EQT Corp., 23 F.4th 256, 260 (3d Cir. 2022).
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`7 Id.
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`5
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`Case: 24-8002 Document: 1-1 Page: 12 Date Filed: 02/07/2024
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`opinions.8 Here, the district court adopted, wholesale, the opinions of
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`Dr. Baker (defendants’ expert), without addressing any of Dr.
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`Rosenthal’s (plaintiffs’ expert) counterpoints. Was the district court’s
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`failure to consider the plaintiffs’ competing expert testimony an error of
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`law?
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`2.
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`The Supreme Court has ruled (1) “Rule 23(b)(3) requires a
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`showing that questions common to the class predominate, not that those
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`questions will be answered, on the merits, in favor of the class”9; and (2)
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`injury occurs the moment a purchaser incurs an overcharge, whether or
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`not that injury is later offset.10 Here, the district court ruled, on the
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`merits, that all class members must prove that they could not have
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`obtained insurance, rebates, or other financial assistance to avoid or
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`8 552 F.3d at 323-25.
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`9 Amgen, 568 U.S. at 459.
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`10 Hawaii v. Standard Oil Co. of Cal., 405 U.S. 251, 262 n.14 (1972)
`(“damages are established by the amount of the overcharge . . . [and]
`courts will not go beyond the fact of this injury to determine whether
`the victim of the overcharge has partially recouped its loss in some
`other way”).
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`6
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`Case: 24-8002 Document: 1-1 Page: 13 Date Filed: 02/07/2024
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`otherwise offset unconscionable and unfair prices. Are those rulings
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`errors of law?
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`3.
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`The New Jersey Supreme Court has held that when a
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`plaintiff overpays due to an unconscionable practice, the plaintiff has
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`suffered an “ascertainable loss” under the NJCFA. The plaintiffs allege
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`they overpaid when they purchased insulin based on the drugs’ list
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`prices, which plaintiffs allege defendants inflated as part of an unlawful
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`scheme. Did the district court err in finding that plaintiffs had not
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`suffered an ascertainable loss?
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`III. ARGUMENT
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`“Contrary to the more limited approaches some other circuits
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`utilize, this Court exercises our very broad discretion using a more
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`liberal standard” for 23(f) petitions.11 This Court has “identified several
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`circumstances in which appellate review is appropriate.”12 Those
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`circumstances include (i) when denial of certification effectively
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`terminates the litigation because the value of each plaintiff’s claim is
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`11 Laudato, 23 F.4th at 260 (internal quotation marks omitted).
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`12 Id. (internal quotation marks omitted).
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`7
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`Case: 24-8002 Document: 1-1 Page: 14 Date Filed: 02/07/2024
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`outweighed by the costs of stand-alone litigation; (ii) when the district
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`court’s class certification determination was erroneous; and (iii) when
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`the appeal might facilitate development of the law on class
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`certification.13
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`A. The Rule 23(f) petition should be granted because the
`district court violated Hydrogen Peroxide when it failed to
`weigh competing expert testimony.
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`The district court’s Rule 23(b)(3) analysis disregards Third Circuit
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`precedent. By adopting—without any analysis—defense expert’s
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`opinions on the types of evidence that will be necessary to prove injury
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`and damages, the district court violated this Court’s directive in
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`Hydrogen Peroxide to weigh competing expert testimony.
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`Hydrogen Peroxide is clear: “Resolving expert disputes in order to
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`determine whether a class certification requirement has been met is
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`always a task for the court.”14 Hydrogen Peroxide clarified that where
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`parties present competing expert evidence bearing on Rule 23(b)(3)’s
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`predominance inquiry, the district court must grapple with both
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`13 Id.
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`14 Hydrogen Peroxide, 552 F.3d at 324.
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`8
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`Case: 24-8002 Document: 1-1 Page: 15 Date Filed: 02/07/2024
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`expert’s opinions. In short, the court must weigh in how the battle of
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`experts may play out before a jury where the conflict bears on a class
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`certification requirement.
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`Here, defendants’ expert, Dr. Lawrence Baker, argued that many
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`diabetics bear the blame for their own high insulin costs due to their
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`choice of insurance plan.15 Dr. Baker speculated that class members
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`struggling to afford insulin16 could have “change[d] jobs, insurance
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`plans, or insurers.”17 Yet, conspicuously, he offered no example of
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`someone who could reasonably have done so, nor any evidence as to the
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`plausibility of his hypotheticals.
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`15 A222.
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`
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`16 See, e.g., Class Cert. Br. at 30-32 (Dkt.# 575) (citing Novo, Sanofi,
`and Lilly documents where the companies acknowledge their high
`prices are causing patients to ration their insulin, leading to
`amputations, blindness, and even death); Pls. Complaint ¶¶ 308-309
`(Dkt.# 411) (“Multiple plaintiffs state that they keep the heat low—even
`in the dead of winter—so they can afford insulin. Parents of children
`with diabetes describe the anguish of not being able to afford pre-
`kindergarten and other educational services for their children due to
`their insulin costs.”).
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`17 A222 (citing Defs.’ Response Br. (citing Baker Rpt. ¶ 102)).
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`9
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`Case: 24-8002 Document: 1-1 Page: 16 Date Filed: 02/07/2024
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`Plaintiffs’ expert, Dr. Meredith Rosenthal, rebutted this claim,
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`explaining how the American healthcare system—wherein people
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`receive insurance through their employers and, regardless, must pick
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`insurance to fit the entire family’s needs—precludes consumers from
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`shopping for a plan based solely on insulin prices.18 Consequently,
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`plaintiffs can prove through common evidence that consumers lack a
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`reasonable way to avoid overcharges by simply “switching insurance.”
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`Dr. Baker also speculated that patients should have searched
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`harder for charities or other programs covering insulin costs.19 Again,
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`he could not cite to one individual who could have secured such
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`charitable assistance. More importantly, Dr. Rosenthal researched the
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`programs Dr. Baker highlighted and showed that, by their own terms,
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`these programs were unavailable to all but a de minimis number of
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`class members.20 Put another way, common evidence rebuts the notion
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`18 See Pls.’ Class Cert. Reply at 5 n.10 (Dkt.# 577) (citing Rosenthal
`Rebuttal Rpt. ¶¶ 10-11).
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`19 A162 n.24, A187.
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`20 See A458-A460 (Rosenthal Rebuttal Rpt. ¶¶ 15-18).
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`10
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`Case: 24-8002 Document: 1-1 Page: 17 Date Filed: 02/07/2024
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`that class members could reasonably mitigate their losses through
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`charity.
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`Dr. Baker also argued that not all uninsured class members paid
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`for their insulin based on the defendants’ list prices because not all
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`pharmacy prices are tied to defendants’ list prices.21 Again, Dr.
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`Rosenthal mathematically rebutted this point using a statistical
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`analysis to show the near-perfect relationship between the list prices
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`defendants set and the point-of-sale prices uninsured consumers pay.22
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`Nor was Dr. Rosenthal’s testimony the only expert evidence offered on
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`this point. Another plaintiffs’ expert, Matthew Wine, explained that all
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`pharmacies set their cash prices using the manufacturer’s list prices.23
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`And as the district court acknowledged in its ascertainability analysis
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`(but curiously not its predominance analysis), the plaintiffs gathered
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`21 Baker Rpt. ¶¶ 148-159 (Dkt.# 576-2).
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`22 See A193.
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`23 See Pls.’ Class Cert. Br. at 18-21 (Dkt.# 575).
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`
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`11
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`Case: 24-8002 Document: 1-1 Page: 18 Date Filed: 02/07/2024
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`declarations from the country’s largest pharmacy chains corroborating
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`this fact.24
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`Lastly, Dr. Baker posits that many plaintiffs may have indirectly
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`benefited from the rebates the defendants paid to pharmacy benefit
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`managers (PBMs).25 He speculates that rebates might trickle down to
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`consumers through eventual lower premiums. But, yet again, he could
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`not show this to be true for any class member. And as Dr. Rosenthal
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`counters, defendants’ rebates to PBMs and insurers do not mitigate the
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`harms of high insulin list prices to consumers because, absent
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`defendants’ misconduct, premiums would have remained the same.26
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`The proposed class, in brief, derives no offsetting benefits from the
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`alleged unlawful scheme.
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`Hydrogen Peroxide requires the district court to contend with Dr.
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`Rosenthal’s testimony. Yet, in its 54-page predominance analysis, the
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`district court does not address a single counter-opinion of Dr.
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`24 A163-A164.
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`
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`25 A131-A132, A223-A224.
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`26 A496-A500 (Rosenthal Rebuttal Rpt. ¶¶ 75-80).
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`
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`12
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`Case: 24-8002 Document: 1-1 Page: 19 Date Filed: 02/07/2024
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`Rosenthal.27 Instead, the district court’s predominance analysis adopts
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`Dr. Baker’s opinions wholesale.28 This is striking given the Court’s
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`extensive Daubert analysis, in which the Court concludes that Dr.
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`Rosenthal testimony on these issues was admissible. Such unreasoned
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`acceptance of the defendants’ expert evidence—and complete disregard
`
`of the plaintiffs’— violates the law of this Circuit as articulated in
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`Hydrogen Peroxide.
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`
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`
`
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`27 In its predominance analysis, the district court references Dr.
`Rosenthal’s opinions only three times: (1) in a summary of the common
`evidence the plaintiffs contend they will use, A193-A194; (2) explaining
`Dr. Rosenthal’s assignment, A198; and (3) to claim that Dr. Rosenthal
`conceded that some proposed class members benefit from rebates—
`when, in reality, the deposition testimony states that non-class
`members can benefit from rebates. A223-A224.
`
`28 See A214, A227, A242.
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`
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`13
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`Case: 24-8002 Document: 1-1 Page: 20 Date Filed: 02/07/2024
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`B. The Rule 23(f) petition should be granted because the
`district court incorrectly ruled that, under state consumer
`protection law, each diabetic patient needs to explain why
`she could not have avoided or otherwise offset the
`defendants’ misconduct.
`
`1.
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`The district court erred—as a matter of law—by
`requiring class members to individually demonstrate
`that they could not have avoided or otherwise offset
`the effect of the defendants’ unconscionable and
`unfair prices.
`
`The district court erred when it focused on hypothetical actions
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`patients could have taken before or after purchasing insulin rather than
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`the common question at the heart of this litigation: did the defendants
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`set unconscionable and unfair prices that the class paid? This error was
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`a legal one: (1) no law requires the plaintiffs to avoid unfair prices for a
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`necessary consumer purchase; and (2) long-standing Supreme Court
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`case law prohibits courts from considering what steps consumers could
`
`have later taken to offset their damages.
`
`First, by focusing on what class members might have done to
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`avoid the defendants’ harm,29 the decision violates the Supreme Court’s
`
`directive that courts determine whether “questions common to the class
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`29 See A214-A216.
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`14
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`predominate, not that those questions will be answered, on the merits,
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`in favor of the class.”30 Put differently, the “focus is on whether the
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`defendant’s conduct was common as to all of the class members, not on
`
`whether each plaintiff has a ‘colorable’ claim.”31 “Merits questions may
`
`be considered to the extent—but only to the extent—that they are
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`relevant to determining whether the Rule 23 prerequisites for class
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`certification are satisfied.”32 Indeed, courts have found, on the merits,
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`that requiring a consumer to search for rebates or other forms of
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`mitigation after the fact is unreasonable.33 So here, a reasonable jury
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`
`30 Amgen, 568 U.S. at 459.
`
`31 Sullivan, 667 F.3d at 299; see also Kalow & Springut, LLP v.
`Commence Corp., 2012 WL 6093876, at *4 (D.N.J. Dec. 7, 2012) (“Not
`only is the same legal issue presented (i.e., is Commence Corporation
`liable under the NJCFA?), common issues of fact will also predominate
`because this suit focuses on ‘the defendant’s conduct’” (quoting Sullivan,
`667 F.3d at 299)).
`
`32 Amgen, 568 U.S. at 466.
`
`33 See, e.g., FTC v. Neovi, Inc., 604 F.3d 1150, 1158 (9th Cir. 2010);
`accord FTC v. Elec. Payment Sols. of Am. Inc., 482 F. Supp. 3d 921, 931
`(D. Ariz. 2020) (“‘obtaining reimbursement require[s] a substantial
`investment of time, trouble, aggravation, and money’” (alteration in
`original)); FTC v. Amazon.com, Inc., 2016 WL 10654030, at *10 (W.D.
`Wash. July 22, 2016) (“customers could [not] reasonably avoid their
`injury by seeking a refund”); In the Matter of Apple Inc., 2014 WL
`
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`
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`15
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`Case: 24-8002 Document: 1-1 Page: 22 Date Filed: 02/07/2024
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`can find—uniformly for all class members—that defendants cannot
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`sidestep liability by requiring class members to avoid the unlawful
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`conduct by jumping through hoops defendants set up.34
`
`The district court nonetheless violated Amgen, holding that, as a
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`matter of law, each class member must prove that they could not have
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`avoided the defendant unfair list prices via insurance switches,
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`insurance purchases, or charitable programs. Indeed, the court’s ruling
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`on the merits that each class member must prove these negative facts
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`precludes a reasonable jury from finding that it is unconscionable and
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`unfair for the defendants to devise a complex scheme that causes class
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`members to pay exorbitant prices. Such an unprecedented merits
`
`
`1330287, at *25 (FTC Mar. 25, 2014) (companies “cannot impose on
`consumers the responsibility for ferreting out material aspects of
`payment systems”); FTC v. Direct Benefits Grp., LLC, 2013 WL
`3771322, at *14 (M.D. Fla. July 18, 2013) (“refunds from Defendants
`do[] not render the injury avoidable”).
`
`34 The defendants also have not shown that any class member was
`eligible for a patient assistance program or coupon she did not use. See
`In re Cmty. Bank of N. Va. Mortg. Lending Pracs. Litig., 795 F.3d 380,
`397 (3d Cir. 2015) (“Because PNC relies solely on speculation, it has not
`demonstrated that the District Court abused its discretion in ruling for
`the Plaintiffs on this [certification] issue.”).
`
`
`
`16
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`Case: 24-8002 Document: 1-1 Page: 23 Date Filed: 02/07/2024
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`ruling, if allowed to stand, would preclude the possibility of class
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`certification in any case alleging unconscionable and unfair pricing for
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`drugs.
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`Second, by focusing on the downstream impact of the defendants’
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`rebates to PBMs, the court violated the well-accepted principle that
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`“injury occurs the moment the purchaser incurs an overcharge, whether
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`or not that injury is later offset.”35 Although this rule most often arises
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`in the antitrust context, the logic applies just as much to consumer
`
`
`35 In re Nexium Antitrust Litig., 777 F.3d 9, 27 (1st Cir. 2015); see
`also Hawaii, 405 U.S. at 262 n.14 (1972) (“damages are established by
`the amount of the overcharge . . . [and] courts will not go beyond the
`fact of this injury to determine whether the victim of the overcharge has
`partially recouped its loss in some other way”); In re Thalomid &
`Revlimid Antitrust Litig., 2018 WL 6573118, at *14 (D.N.J. Oct. 30,
`2018) (“any amounts that such Plan Sponsors received . . . in the form of
`rebates is irrelevant to the question of impact”); In re Solodyn
`(Minocycline Hydrochloride) Antitrust Litig., 2017 WL 4621777, at *15
`(D. Mass. Oct. 16, 2017) (“[E]ven if putative class members were
`reimbursed for overcharges through insurance plans or coupons, they
`still experienced antitrust injury in the form of an overcharge . . . .”); In
`re Lidoderm Antitrust Litig., 2017 WL 679367, at *21 (N.D. Cal. Feb.
`21, 2017) (“[A] person suffers a cognizable injury . . . the moment he
`pays an antitrust overcharge, even if the anticompetitive conduct at
`issue also results in offsetting benefits.”).
`
`
`
`17
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`Case: 24-8002 Document: 1-1 Page: 24 Date Filed: 02/07/2024
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`fraud cases: “[a]s long as the seller continues to charge the illegal price,
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`he takes from the buyer more than the law allows.”36
`
`The district court held that the possibility later rebates to PBMs—
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`rebates that occurred months after the consumers’ purchases—would
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`trickle down to the patients in the form of future lower premiums,
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`offsetting their damages, created an individualized issue that precludes
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`class certification.37 This holding violates long-standing and
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`unequivocal Supreme Court precedent on damage offsets. For example,
`
`in Southern Pacific Co. v. Darnell-Taenzer Lumber Co., the Supreme
`
`Court examined whether a defendant could reduce a plaintiff’s damages
`
`when “the plaintiffs were able to pass on the [overcharge].”38 To that
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`question, the Court responded, “[t]he answer is not difficult”: “[t]he
`
`
`36 Hanover Shoe, Inc. v. United Shoe Mach. Corp., 392 U.S. 481, 489
`(1968); see also Atl. City Elec. Co. v. Gen. Elec. Co., 226 F. Supp. 59, 64–
`65 (S.D.N.Y. 1964) (the law “prevents attributing ‘remote consequences’
`to a defendant” and “a defendant will be held liable to a plaintiff which
`it causes to suffer a proximate loss; otherwise a defendant could escape
`civil liability altogether”).
`
`37 A214 (holding that “[i]ndividualized inquiries will also be required
`to determine whether and how putative class members benefited from
`the rebates” to pharmacy benefit managers).
`
`38 245 U.S. 531, 533 (1918).
`
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`general tendency of the law, in regard to damages at least, is not to go
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`beyond the first step.”39 Because a plaintiff’s injury and, therefore,
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`damages “claim accrue[s] at once in the theory of the law,” the Court
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`“does not inquire into later events.”40 Here, the law precludes
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`defendants’ argument that their rebates later offset plaintiffs’ damages
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`and creates individualized issues.
`
`In any event, as plaintiffs argued in the district court,41
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`defendants must prove that passed-through rebate