Allegations
(a) defendants had engaged in a scheme to artificially inflate the sales of Suboxone Film by more than $3 billion by falsely touting the drug’s purportedly superior efficacy and safety as compared to tablets; (b) contrary to defendants’ public statements, the FDA and internal Company documents had concluded that Suboxone Film posed a potentially greater risk of abuse and child endangerment than other available treatments; (c) defendants had fabricated a safety scare involving Suboxone Tablets in order to unlawfully delay and prevent generic competition; (d) defendants had engaged in a massive marketing campaign that had misrepresented the purported benefits of Suboxone Film as compared to Suboxone Tablets to doctors, healthcare providers, government regulators and investors; (e) defendants had encouraged Suboxone sales through medical providers that they knew were overprescribing the drug, facilitating the drug’s abuse and/or prescribing it in a careless and clinically unwarranted manner, often to hundreds of individuals at a time; (f) as a result of (a)-(e) above, Reckitt’s revenues, net income an d earnings were artificially inflated and the product of illicit business practices; and (g) as a result of (a)-(f) above, Reckitt and Reckitt Pharma were exposed to extraordinary undisclosed legal and reputational risks that could result in billions of dollars in fines, lost business and legal judgments or other monetary penalties.