Actavis, Inc. a corporation, and Warner Chilott PLC; Analysis of Agreement Containing Consent Orders To Aid Public Comment, 65313-65315 [2013-25847]
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Federal Register / Vol. 78, No. 211 / Thursday, October 31, 2013 / Notices
received at the Reserve Bank indicated
or the offices of the Board of Governors
not later than November 25, 2013.
A. Federal Reserve Bank of
Philadelphia (William Lang, Senior Vice
President) 100 North 6th Street,
Philadelphia, Pennsylvania 19105–
1521:
1. Liberty Centre Bancorp, Inc.,
Pottsville, Pennsylvania; to merge with
and into GNB Financial Services, Inc.,
Gratz, Pennsylvania, and thereby
indirectly acquire voting shares of
Liberty Savings Bank, FSB, Pottsville,
Pennsylvania, and engage in operating a
savings and loan association, pursuant
to section 225.28(b)(4)(ii).
Board of Governors of the Federal Reserve
System, October 28, 2013.
Michael J. Lewandowski,
Associate Secretary of the Board.
[FR Doc. 2013–25937 Filed 10–30–13; 8:45 am]
BILLING CODE 6210–01–P
FEDERAL TRADE COMMISSION
[File No. 131 0152]
Actavis, Inc. a corporation, and Warner
Chilott PLC; Analysis of Agreement
Containing Consent Orders To Aid
Public Comment
Federal Trade Commission.
Proposed Consent Agreement.
AGENCY:
ACTION:
The consent agreement in this
matter settles alleged violations of
federal law prohibiting unfair or
deceptive acts or practices or unfair
methods of competition. The attached
Analysis to Aid Public Comment
describes both the allegations in the
draft complaint and the terms of the
consent orders—embodied in the
consent agreement—that would settle
these allegations.
DATES: Comments must be received on
or before November 12, 2013.
ADDRESSES: Interested parties may file a
comment at https://
ftcpublic.commentworks.com/ftc/
activiswarnerconsent online or on
paper, by following the instructions in
the Request for Comment part of the
SUPPLEMENTARY INFORMATION section
below. Write ‘‘Actavis Warner, File No.
131 0152’’ on your comment and file
your comment online at https://
ftcpublic.commentworks.com/ftc/
actaviswarnerconsent following the
instructions on the web-based form. If
you prefer to file your comment on
paper, mail or deliver your comment to
the following address: Federal Trade
Commission, Office of the Secretary,
Room H–113 (Annex D), 600
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SUMMARY:
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Pennsylvania Avenue NW., Washington,
DC 20580.
FOR FURTHER INFORMATION CONTACT: Keri
Wallace (202–326–3085), FTC, Bureau
of Competition, 600 Pennsylvania
Avenue NW., Washington, DC 20580.
SUPPLEMENTARY INFORMATION: Pursuant
to Section 6(f) of the Federal Trade
Commission Act, 15 U.S.C. 46(f), and
FTC Rule 2.34, 16 CFR 2.34, notice is
hereby given that the above-captioned
consent agreement containing a consent
order to cease and desist, having been
filed with and accepted, subject to final
approval, by the Commission, has been
placed on the public record for a period
of thirty (30) days. The following
Analysis to Aid Public Comment
describes the terms of the consent
agreement, and the allegations in the
complaint. An electronic copy of the
full text of the consent agreement
package can be obtained from the FTC
Home Page (for September 27, 2013), on
the World Wide Web, at https://
www.ftc.gov/os/actions.shtm. A paper
copy can be obtained from the FTC
Public Reference Room, Room 130–H,
600 Pennsylvania Avenue NW.,
Washington, DC 20580, either in person
or by calling (202) 326–2222.
You can file a comment online or on
paper. For the Commission to consider
your comment, we must receive it on or
before November 12, 2013. Write
‘‘Actavis Warner, File No. 131 0152’’ on
your comment. Your comment—
including your name and your state—
will be placed on the public record of
this proceeding, including, to the extent
practicable, on the public Commission
Web site, at https://www.ftc.gov/os/
publiccomments.shtm. As a matter of
discretion, the Commission tries to
remove individuals’ home contact
information from comments before
placing them on the Commission Web
site.
Because your comment will be made
public, you are solely responsible for
making sure that your comment does
not include any sensitive personal
information, like anyone’s Social
Security number, date of birth, driver’s
license number or other state
identification number or foreign country
equivalent, passport number, financial
account number, or credit or debit card
number. You are also solely responsible
for making sure that your comment does
not include any sensitive health
information, like medical records or
other individually identifiable health
information. In addition, do not include
any ‘‘[t]rade secret or any commercial or
financial information which . . . is
privileged or confidential,’’ as discussed
in Section 6(f) of the FTC Act, 15 U.S.C.
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65313
46(f), and FTC Rule 4.10(a)(2), 16 CFR
4.10(a)(2). In particular, do not include
competitively sensitive information
such as costs, sales statistics,
inventories, formulas, patterns, devices,
manufacturing processes, or customer
names.
If you want the Commission to give
your comment confidential treatment,
you must file it in paper form, with a
request for confidential treatment, and
you have to follow the procedure
explained in FTC Rule 4.9(c), 16 CFR
4.9(c).1 Your comment will be kept
confidential only if the FTC General
Counsel, in his or her sole discretion,
grants your request in accordance with
the law and the public interest.
Postal mail addressed to the
Commission is subject to delay due to
heightened security screening. As a
result, we encourage you to submit your
comments online. To make sure that the
Commission considers your online
comment, you must file it at https://
ftcpublic.commentworks.com/ftc/
actaviswarnerconsent by following the
instructions on the web-based form. If
this Notice appears at https://
www.regulations.gov/#!home you also
may file a comment through that Web
site.
If you file your comment on paper,
write ‘‘Actavis Warner, File No. 131
0152’’ on your comment and on the
envelope, and mail or deliver it to the
following address: Federal Trade
Commission, Office of the Secretary,
Room H–113 (Annex D), 600
Pennsylvania Avenue NW., Washington,
DC 20580. If possible, submit your
paper comment to the Commission by
courier or overnight service.
Visit the Commission Web site at
https://www.ftc.gov to read this Notice
and the news release describing it. The
FTC Act and other laws that the
Commission administers permit the
collection of public comments to
consider and use in this proceeding as
appropriate. The Commission will
consider all timely and responsive
public comments that it receives on or
before November 12, 2013. You can find
more information, including routine
uses permitted by the Privacy Act, in
the Commission’s privacy policy, at
https://www.ftc.gov/ftc/privacy.htm.
Analysis of Agreement Containing
Consent Order To Aid Public Comment
The Federal Trade Commission
(‘‘Commission’’) has accepted, subject to
1 In particular, the written request for confidential
treatment that accompanies the comment must
include the factual and legal basis for the request,
and must identify the specific portions of the
comment to be withheld from the public record. See
FTC Rule 4.9(c), 16 CFR 4.9(c).
E:\FR\FM\31OCN1.SGM
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65314
Federal Register / Vol. 78, No. 211 / Thursday, October 31, 2013 / Notices
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final approval, an Agreement
Containing Consent Orders (‘‘Consent
Agreement’’) from Actavis, Inc.
(‘‘Actavis’’) and Warner Chilcott plc
(‘‘Warner Chilcott’’) that is designed to
remedy the anticompetitive effects of
Actavis’s proposed acquisition of
Warner Chilcott. Under the terms of the
proposed Consent Agreement, Actavis
would be required to divest to Amneal
Pharmaceuticals L.L.C. (‘‘Amneal’’) all
of Actavis’s rights and assets relating to
generic versions of the drugs Femcon
FE, Loestrin 24 FE, Lo Loestrin FE, and
Atelvia. Actavis will also enter into an
agreement to supply generic versions of
the Femcon FE and Loestrin 24 FE
products to Amneal for a period of two
years, which Amneal has the option to
extend for up to two additional one-year
terms if it chooses.
The proposed Consent Agreement has
been placed on the public record for
thirty days for receipt of comments by
interested persons. Comments received
during this period will become part of
the public record. After thirty days, the
Commission will again review the
proposed Consent Agreement and the
comments received, and will decide
whether it should withdraw from the
proposed Consent Agreement, modify it,
or make final the Decision and Order
(‘‘Order’’).
Pursuant to a Transaction Agreement
dated May 19, 2013, Actavis proposes to
acquire Warner Chilcott in a transaction
valued at approximately $8.5 billion
(‘‘Proposed Acquisition’’). The
Commission’s Complaint alleges that
the Proposed Acquisition, if
consummated, would violate Section 7
of the Clayton Act, as amended, 15
U.S.C. 18, and Section 5 of the Federal
Trade Commission Act, as amended, 15
U.S.C. 45, by lessening competition in
the U.S. markets for (1) Generic Femcon
FE, (2) Loestrin 24 FE and its generic
equivalents, (3) Lo Loestrin FE and its
generic equivalents, and (4) Atelvia and
its generic equivalents. The proposed
Consent Agreement will remedy the
alleged violations by replacing the
competition that would otherwise be
eliminated by the Proposed Acquisition.
The Impact of Generics in
Pharmaceutical Markets
In human pharmaceutical product
markets, price generally decreases as the
number of generic competitors
increases. Accordingly, the reduction in
the number of suppliers within each
relevant market has a direct and
substantial effect on pricing. When the
first generic version of a drug enters the
market, it typically competes by selling
at a discount to the branded drug. At
that point, the brand typically loses
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most of its sales to the generic version.
During the period in which only one
generic product is available, the price
for the branded product acts as a ceiling
above which the generic manufacturer
cannot price its product. In most cases,
once additional generic versions of the
drug enter the market, competition
among the generic competitors drives
generic pricing down further. Prices
continue to decrease incrementally with
the entry of the second, third, fourth,
and even fifth generic oral
pharmaceutical competitor.
Generic drugs are typically launched
upon the expiration of the branded
product’s patents. If the generic
company intends to launch its product
before the expiration of the branded
product’s patents, it must notify the
FDA and certify that its product does
not infringe the branded company’s
patent or that the branded company’s
patents are invalid. This is referred to as
a Paragraph IV certification. A
Paragraph IV certification typically
leads to patent infringement litigation
between the generic company and
branded company. The first company to
file a Paragraph IV ANDA has the right
to market its generic drug exclusively
for a period of 180 days if it is
successful in its litigation against the
branded drug manufacturer.2 No other
firm, even those that subsequently
submit Paragraph IV ANDAs, may enter
the generic market until after the
conclusion of this marketing exclusivity
period. The prospect of earning higher
profits as the only firm marketing a
generic version of a drug for 180 days
provides an incentive to defend against
the patent infringement claims brought
by the brand drug manufacturer. Thus,
the firm with exclusivity usually takes
the leading role, and invests the greatest
resources, in these cases.
The Proposed Acquisition Would
Reduce the Number of Suppliers in the
Four Relevant Markets
Femcon FE is a chewable oral
contraceptive tablet that contains
progestin and estrogen. Warner Chilcott
manufactures and markets the branded
version of the drug. Only two
companies—Warner Chilcott (via an
authorized generic it supplies to Lupin
Ltd.3) and Actavis—currently sell
2 Uncertainty occasionally exists regarding
whether a Paragraph IV ANDA has been filed
properly, which creates uncertainty about whether
a company is eligible to receive marketing
exclusivity rights from the FDA. In addition, the
FDA sometimes determines that more than one
company is eligible for market exclusivity rights
based on the timing of their filings.
3 Branded pharmaceutical companies, such as
Warner Chilcott, manufacture authorized generic
products for sale under a non-brand label at generic
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significant volumes of generic Femcon
FE in the United States. Teva
Pharmaceutical Industries Ltd. (‘‘Teva’’)
also has approval from the FDA to sell
generic Femcon FE, but it has made
only de minimis sales of this product
since 2011. In 2012, Actavis had
approximately 70 percent of generic
sales, while Warner Chilcott had
approximately 30 percent. Therefore,
the proposed acquisition combines two
of the three firms approved to supply
generic Femcon FE, and the only two
significant suppliers of this drug today.
Loestrin 24 FE is a low-dose
progestin/estrogen combination oral
contraceptive product. Warner Chilcott
manufactures and markets the branded
version of the drug. No companies
currently market a generic version of
Loestrin 24 FE. Actavis is likely to be
the first generic supplier to compete
against Warner Chilcott and no other
firm is likely to enter the market for
generic Loestrin 24 FE in time to
prevent the anticompetitive effects from
the Proposed Acquisition.
Lo Loestrin FE is another low-dose
progestin/estrogen combination oral
contraceptive product. Warner Chilcott
manufactures and markets the branded
version of the drug. No companies
currently market a generic version of Lo
Loestrin FE, but Lupin and Actavis each
plan to launch a generic product. Both
companies are currently engaged in
patent litigation with the brand drug
manufacturer, but it remains uncertain
which firm would receive marketing
exclusivity rights from the FDA if it
succeeded in defending against Warner
Chilcott’s claims. Thus, absent the
acquisition, Actavis may be the first and
only generic competitor to the Warner
Chilcott branded product for a period of
180 days.
Atelvia is a delayed-release tablet
containing risedronate sodium that is
used to treat postmenopausal
osteoporosis. Warner Chilcott markets
the branded version of the drug. No
generic version of the product is
currently available in the United States.
Actavis, Teva, and Ranbaxy Laboratories
Limited all plan to market generic
versions of Atelvia, and all three
companies are currently engaged in
patent litigation with Warner Chilcott.
However, uncertainty remains about
which one will have marketing
exclusivity rights if successful in the
litigation. Thus, absent the acquisition,
Actavis may be the first and only
generic competitor to Warner Chilcott’s
prices. In this case, Warner Chilcott has contracted
with Lupin to market the authorized generic version
of Femcon FE, though in other markets a branded
drug company may market its own generic product.
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Federal Register / Vol. 78, No. 211 / Thursday, October 31, 2013 / Notices
branded product for a period of 180
days.
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Entry Into the Relevant Markets
Entry Into the markets for generic
Femcon FE, Lo Loestrin 24 and its
generic equivalents, Loestrin 24 FE and
its generic equivalents, and Atelvia and
its generic equivalents would not be
timely, likely, or sufficient in
magnitude, character, and scope to deter
or counteract the anticompetitive effects
of the acquisition. De novo entry would
not take place in a timely manner
because the combination of drug
development times and FDA approval
requirements would delay entry by at
least two years. Even companies for
which the FDA approval process is well
underway face additional barriers,
including Hatch-Waxman regulatory
exclusivity and pending patent
litigation, that prevent them from
entering these markets in time to deter
the price increases that would occur
after consummation of the Proposed
Acquisition.
The Anticompetitive Effects of the
Acquisition
The Proposed Acquisition would
cause significant anticompetitive harm
to consumers in the U.S. markets for
generic Femcon FE, Lo Loestrin 24 and
its generic equivalents, Lo Loestrin FE
and its generic equivalents, and Atelvia
and its generic equivalents. The
Proposed Acquisition would eliminate
the current competition between the
only two significant suppliers of generic
Femcon FE, leading to significantly
higher prices for this drug. The
acquisition may also delay the onset of
beneficial generic competition in the
markets for Loestrin 24 FE, Lo Loestrin
FE, and Atelvia. Evidence, including
information regarding the status of the
FDA approval process for potential
suppliers of generic Loestrin 24 FE,
suggests that Actavis will be the first
generic supplier to compete against
Warner Chilcott’s branded product.
Moreover, no other generic supplier is
likely to enter the market for a
significant period of time. Thus, the
combined firm would likely delay the
entry of Actavis’s generic version of
Loestrin 24 FE or, at a minimum, cause
Actavis’s generic drug to compete less
vigorously against Warner Chilcott’s
branded product, resulting in higher
prices for consumers. Similarly, in the
markets for Lo Loestrin FE and Atelvia,
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Actavis may be the first and only
generic competitor to Warner Chilcott’s
branded products for a significant
period absent the Proposed Acquisition.
By eliminating this potential
competition between Warner Chilcott
and Actavis in each of these markets,
the Proposed Acquisition would harm
U.S. consumers by substantially
increasing the likelihood of higher postacquisition prices for Lo Loestrin FE
and Atelvia.
The Proposed Consent Agreement
The proposed Consent Agreement
effectively remedies the Proposed
Acquisition’s anticompetitive effects in
the relevant markets by requiring
Actavis to divest to Amneal certain
rights and assets related to generic
Femcon FE, generic Loestrin 24 FE,
generic Lo Loestrin FE, and generic
Atelvia no later than ten days after
consummating the acquisition. In
addition, the Consent Agreement
requires Actavis to enter into a supply
agreement to provide Amneal with
generic versions of the Femcon FE and
Loestrin 24 FE products to sell in the
United States for up to four years.
Amneal is a New Jersey-based generic
pharmaceutical company that currently
markets 65 products and maintains an
active product development pipeline.
With its experience in generic markets,
Amneal is well positioned to replicate
the competition that would otherwise be
lost as a result of the Proposed
Acquisition.
If the Commission determines that
Amneal is not an acceptable acquirer of
the assets to be divested, or that the
manner of the divestitures is not
acceptable, Actavis must unwind the
sale to Amneal and divest the products
within six months of the date the Order
becomes final, to a Commissionapproved acquirer. If Actavis fails to
divest the products as required, the
Commission may appoint a trustee to
divest the products.
The proposed Consent Agreement
contains several provisions to help
ensure that the divestitures are
successful. The Order requires Actavis
to maintain the economic viability,
marketability, and competitiveness of
the divestiture products until such time
as they are transferred to Amneal or
another Commission-approved acquirer.
Actavis must also transfer the
manufacturing technology for the
divestiture products to Amneal and
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65315
supply Amneal with the generic
Femcon FE and Loestrin 24 FE products
during the transition period. In
addition, the Consent Agreement
requires Actavis to relinquish any claim
to marketing exclusivity for generic Lo
Loestrin FE and Atelvia products to
ensure that the incentives of the
companies currently leading the patent
litigations relating to those products do
not change.
The purpose of this analysis is to
facilitate public comment on the
proposed Consent Agreement, and it is
not intended to constitute an official
interpretation of the proposed Order or
to modify its terms in any way.
By direction of the Commission.
Donald S. Clark
Secretary.
[FR Doc. 2013–25847 Filed 10–30–13; 8:45 am]
BILLING CODE 6750–01–P
FEDERAL TRADE COMMISSION
Granting of Request for Early
Termination of the Waiting Period
Under the Premerger Notification
Rules
Section 7A of the Clayton Act, 15
U.S.C. 18a, as added by Title II of the
Hart-Scott-Rodino Antitrust
Improvements Act of 1976, requires
persons contemplating certain mergers
or acquisitions to give the Federal Trade
Commission and the Assistant Attorney
General advance notice and to wait
designated periods before
consummation of such plans. Section
7A(b)(2) of the Act permits the agencies,
in individual cases, to terminate this
waiting period prior to its expiration
and requires that notice of this action be
published in the Federal Register.
The following transactions were
granted early termination—on the dates
indicated—of the waiting period
provided by law and the premerger
notification rules. The listing for each
transaction includes the transaction
number and the parties to the
transaction. The grants were made by
the Federal Trade Commission and the
Assistant Attorney General for the
Antitrust Division of the Department of
Justice. Neither agency intends to take
any action with respect to these
proposed acquisitions during the
applicable waiting period.
E:\FR\FM\31OCN1.SGM
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Agencies
[Federal Register Volume 78, Number 211 (Thursday, October 31, 2013)]
[Notices]
[Pages 65313-65315]
From the Federal Register Online via the Government Printing Office [www.gpo.gov]
[FR Doc No: 2013-25847]
=======================================================================
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FEDERAL TRADE COMMISSION
[File No. 131 0152]
Actavis, Inc. a corporation, and Warner Chilott PLC; Analysis of
Agreement Containing Consent Orders To Aid Public Comment
AGENCY: Federal Trade Commission.
ACTION: Proposed Consent Agreement.
-----------------------------------------------------------------------
SUMMARY: The consent agreement in this matter settles alleged
violations of federal law prohibiting unfair or deceptive acts or
practices or unfair methods of competition. The attached Analysis to
Aid Public Comment describes both the allegations in the draft
complaint and the terms of the consent orders--embodied in the consent
agreement--that would settle these allegations.
DATES: Comments must be received on or before November 12, 2013.
ADDRESSES: Interested parties may file a comment at https://ftcpublic.commentworks.com/ftc/activiswarnerconsent online or on paper,
by following the instructions in the Request for Comment part of the
SUPPLEMENTARY INFORMATION section below. Write ``Actavis Warner, File
No. 131 0152'' on your comment and file your comment online at https://ftcpublic.commentworks.com/ftc/actaviswarnerconsent following the
instructions on the web-based form. If you prefer to file your comment
on paper, mail or deliver your comment to the following address:
Federal Trade Commission, Office of the Secretary, Room H-113 (Annex
D), 600 Pennsylvania Avenue NW., Washington, DC 20580.
FOR FURTHER INFORMATION CONTACT: Keri Wallace (202-326-3085), FTC,
Bureau of Competition, 600 Pennsylvania Avenue NW., Washington, DC
20580.
SUPPLEMENTARY INFORMATION: Pursuant to Section 6(f) of the Federal
Trade Commission Act, 15 U.S.C. 46(f), and FTC Rule 2.34, 16 CFR 2.34,
notice is hereby given that the above-captioned consent agreement
containing a consent order to cease and desist, having been filed with
and accepted, subject to final approval, by the Commission, has been
placed on the public record for a period of thirty (30) days. The
following Analysis to Aid Public Comment describes the terms of the
consent agreement, and the allegations in the complaint. An electronic
copy of the full text of the consent agreement package can be obtained
from the FTC Home Page (for September 27, 2013), on the World Wide Web,
at https://www.ftc.gov/os/actions.shtm. A paper copy can be obtained
from the FTC Public Reference Room, Room 130-H, 600 Pennsylvania Avenue
NW., Washington, DC 20580, either in person or by calling (202) 326-
2222.
You can file a comment online or on paper. For the Commission to
consider your comment, we must receive it on or before November 12,
2013. Write ``Actavis Warner, File No. 131 0152'' on your comment. Your
comment--including your name and your state--will be placed on the
public record of this proceeding, including, to the extent practicable,
on the public Commission Web site, at https://www.ftc.gov/os/publiccomments.shtm. As a matter of discretion, the Commission tries to
remove individuals' home contact information from comments before
placing them on the Commission Web site.
Because your comment will be made public, you are solely
responsible for making sure that your comment does not include any
sensitive personal information, like anyone's Social Security number,
date of birth, driver's license number or other state identification
number or foreign country equivalent, passport number, financial
account number, or credit or debit card number. You are also solely
responsible for making sure that your comment does not include any
sensitive health information, like medical records or other
individually identifiable health information. In addition, do not
include any ``[t]rade secret or any commercial or financial information
which . . . is privileged or confidential,'' as discussed in Section
6(f) of the FTC Act, 15 U.S.C. 46(f), and FTC Rule 4.10(a)(2), 16 CFR
4.10(a)(2). In particular, do not include competitively sensitive
information such as costs, sales statistics, inventories, formulas,
patterns, devices, manufacturing processes, or customer names.
If you want the Commission to give your comment confidential
treatment, you must file it in paper form, with a request for
confidential treatment, and you have to follow the procedure explained
in FTC Rule 4.9(c), 16 CFR 4.9(c).\1\ Your comment will be kept
confidential only if the FTC General Counsel, in his or her sole
discretion, grants your request in accordance with the law and the
public interest.
---------------------------------------------------------------------------
\1\ In particular, the written request for confidential
treatment that accompanies the comment must include the factual and
legal basis for the request, and must identify the specific portions
of the comment to be withheld from the public record. See FTC Rule
4.9(c), 16 CFR 4.9(c).
---------------------------------------------------------------------------
Postal mail addressed to the Commission is subject to delay due to
heightened security screening. As a result, we encourage you to submit
your comments online. To make sure that the Commission considers your
online comment, you must file it at https://ftcpublic.commentworks.com/ftc/actaviswarnerconsent by following the instructions on the web-based
form. If this Notice appears at https://www.regulations.gov/#!home you
also may file a comment through that Web site.
If you file your comment on paper, write ``Actavis Warner, File No.
131 0152'' on your comment and on the envelope, and mail or deliver it
to the following address: Federal Trade Commission, Office of the
Secretary, Room H-113 (Annex D), 600 Pennsylvania Avenue NW.,
Washington, DC 20580. If possible, submit your paper comment to the
Commission by courier or overnight service.
Visit the Commission Web site at https://www.ftc.gov to read this
Notice and the news release describing it. The FTC Act and other laws
that the Commission administers permit the collection of public
comments to consider and use in this proceeding as appropriate. The
Commission will consider all timely and responsive public comments that
it receives on or before November 12, 2013. You can find more
information, including routine uses permitted by the Privacy Act, in
the Commission's privacy policy, at https://www.ftc.gov/ftc/privacy.htm.
Analysis of Agreement Containing Consent Order To Aid Public Comment
The Federal Trade Commission (``Commission'') has accepted, subject
to
[[Page 65314]]
final approval, an Agreement Containing Consent Orders (``Consent
Agreement'') from Actavis, Inc. (``Actavis'') and Warner Chilcott plc
(``Warner Chilcott'') that is designed to remedy the anticompetitive
effects of Actavis's proposed acquisition of Warner Chilcott. Under the
terms of the proposed Consent Agreement, Actavis would be required to
divest to Amneal Pharmaceuticals L.L.C. (``Amneal'') all of Actavis's
rights and assets relating to generic versions of the drugs Femcon FE,
Loestrin 24 FE, Lo Loestrin FE, and Atelvia. Actavis will also enter
into an agreement to supply generic versions of the Femcon FE and
Loestrin 24 FE products to Amneal for a period of two years, which
Amneal has the option to extend for up to two additional one-year terms
if it chooses.
The proposed Consent Agreement has been placed on the public record
for thirty days for receipt of comments by interested persons. Comments
received during this period will become part of the public record.
After thirty days, the Commission will again review the proposed
Consent Agreement and the comments received, and will decide whether it
should withdraw from the proposed Consent Agreement, modify it, or make
final the Decision and Order (``Order'').
Pursuant to a Transaction Agreement dated May 19, 2013, Actavis
proposes to acquire Warner Chilcott in a transaction valued at
approximately $8.5 billion (``Proposed Acquisition''). The Commission's
Complaint alleges that the Proposed Acquisition, if consummated, would
violate Section 7 of the Clayton Act, as amended, 15 U.S.C. 18, and
Section 5 of the Federal Trade Commission Act, as amended, 15 U.S.C.
45, by lessening competition in the U.S. markets for (1) Generic Femcon
FE, (2) Loestrin 24 FE and its generic equivalents, (3) Lo Loestrin FE
and its generic equivalents, and (4) Atelvia and its generic
equivalents. The proposed Consent Agreement will remedy the alleged
violations by replacing the competition that would otherwise be
eliminated by the Proposed Acquisition.
The Impact of Generics in Pharmaceutical Markets
In human pharmaceutical product markets, price generally decreases
as the number of generic competitors increases. Accordingly, the
reduction in the number of suppliers within each relevant market has a
direct and substantial effect on pricing. When the first generic
version of a drug enters the market, it typically competes by selling
at a discount to the branded drug. At that point, the brand typically
loses most of its sales to the generic version. During the period in
which only one generic product is available, the price for the branded
product acts as a ceiling above which the generic manufacturer cannot
price its product. In most cases, once additional generic versions of
the drug enter the market, competition among the generic competitors
drives generic pricing down further. Prices continue to decrease
incrementally with the entry of the second, third, fourth, and even
fifth generic oral pharmaceutical competitor.
Generic drugs are typically launched upon the expiration of the
branded product's patents. If the generic company intends to launch its
product before the expiration of the branded product's patents, it must
notify the FDA and certify that its product does not infringe the
branded company's patent or that the branded company's patents are
invalid. This is referred to as a Paragraph IV certification. A
Paragraph IV certification typically leads to patent infringement
litigation between the generic company and branded company. The first
company to file a Paragraph IV ANDA has the right to market its generic
drug exclusively for a period of 180 days if it is successful in its
litigation against the branded drug manufacturer.\2\ No other firm,
even those that subsequently submit Paragraph IV ANDAs, may enter the
generic market until after the conclusion of this marketing exclusivity
period. The prospect of earning higher profits as the only firm
marketing a generic version of a drug for 180 days provides an
incentive to defend against the patent infringement claims brought by
the brand drug manufacturer. Thus, the firm with exclusivity usually
takes the leading role, and invests the greatest resources, in these
cases.
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\2\ Uncertainty occasionally exists regarding whether a
Paragraph IV ANDA has been filed properly, which creates uncertainty
about whether a company is eligible to receive marketing exclusivity
rights from the FDA. In addition, the FDA sometimes determines that
more than one company is eligible for market exclusivity rights
based on the timing of their filings.
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The Proposed Acquisition Would Reduce the Number of Suppliers in the
Four Relevant Markets
Femcon FE is a chewable oral contraceptive tablet that contains
progestin and estrogen. Warner Chilcott manufactures and markets the
branded version of the drug. Only two companies--Warner Chilcott (via
an authorized generic it supplies to Lupin Ltd.\3\) and Actavis--
currently sell significant volumes of generic Femcon FE in the United
States. Teva Pharmaceutical Industries Ltd. (``Teva'') also has
approval from the FDA to sell generic Femcon FE, but it has made only
de minimis sales of this product since 2011. In 2012, Actavis had
approximately 70 percent of generic sales, while Warner Chilcott had
approximately 30 percent. Therefore, the proposed acquisition combines
two of the three firms approved to supply generic Femcon FE, and the
only two significant suppliers of this drug today.
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\3\ Branded pharmaceutical companies, such as Warner Chilcott,
manufacture authorized generic products for sale under a non-brand
label at generic prices. In this case, Warner Chilcott has
contracted with Lupin to market the authorized generic version of
Femcon FE, though in other markets a branded drug company may market
its own generic product.
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Loestrin 24 FE is a low-dose progestin/estrogen combination oral
contraceptive product. Warner Chilcott manufactures and markets the
branded version of the drug. No companies currently market a generic
version of Loestrin 24 FE. Actavis is likely to be the first generic
supplier to compete against Warner Chilcott and no other firm is likely
to enter the market for generic Loestrin 24 FE in time to prevent the
anticompetitive effects from the Proposed Acquisition.
Lo Loestrin FE is another low-dose progestin/estrogen combination
oral contraceptive product. Warner Chilcott manufactures and markets
the branded version of the drug. No companies currently market a
generic version of Lo Loestrin FE, but Lupin and Actavis each plan to
launch a generic product. Both companies are currently engaged in
patent litigation with the brand drug manufacturer, but it remains
uncertain which firm would receive marketing exclusivity rights from
the FDA if it succeeded in defending against Warner Chilcott's claims.
Thus, absent the acquisition, Actavis may be the first and only generic
competitor to the Warner Chilcott branded product for a period of 180
days.
Atelvia is a delayed-release tablet containing risedronate sodium
that is used to treat postmenopausal osteoporosis. Warner Chilcott
markets the branded version of the drug. No generic version of the
product is currently available in the United States. Actavis, Teva, and
Ranbaxy Laboratories Limited all plan to market generic versions of
Atelvia, and all three companies are currently engaged in patent
litigation with Warner Chilcott. However, uncertainty remains about
which one will have marketing exclusivity rights if successful in the
litigation. Thus, absent the acquisition, Actavis may be the first and
only generic competitor to Warner Chilcott's
[[Page 65315]]
branded product for a period of 180 days.
Entry Into the Relevant Markets
Entry Into the markets for generic Femcon FE, Lo Loestrin 24 and
its generic equivalents, Loestrin 24 FE and its generic equivalents,
and Atelvia and its generic equivalents would not be timely, likely, or
sufficient in magnitude, character, and scope to deter or counteract
the anticompetitive effects of the acquisition. De novo entry would not
take place in a timely manner because the combination of drug
development times and FDA approval requirements would delay entry by at
least two years. Even companies for which the FDA approval process is
well underway face additional barriers, including Hatch-Waxman
regulatory exclusivity and pending patent litigation, that prevent them
from entering these markets in time to deter the price increases that
would occur after consummation of the Proposed Acquisition.
The Anticompetitive Effects of the Acquisition
The Proposed Acquisition would cause significant anticompetitive
harm to consumers in the U.S. markets for generic Femcon FE, Lo
Loestrin 24 and its generic equivalents, Lo Loestrin FE and its generic
equivalents, and Atelvia and its generic equivalents. The Proposed
Acquisition would eliminate the current competition between the only
two significant suppliers of generic Femcon FE, leading to
significantly higher prices for this drug. The acquisition may also
delay the onset of beneficial generic competition in the markets for
Loestrin 24 FE, Lo Loestrin FE, and Atelvia. Evidence, including
information regarding the status of the FDA approval process for
potential suppliers of generic Loestrin 24 FE, suggests that Actavis
will be the first generic supplier to compete against Warner Chilcott's
branded product. Moreover, no other generic supplier is likely to enter
the market for a significant period of time. Thus, the combined firm
would likely delay the entry of Actavis's generic version of Loestrin
24 FE or, at a minimum, cause Actavis's generic drug to compete less
vigorously against Warner Chilcott's branded product, resulting in
higher prices for consumers. Similarly, in the markets for Lo Loestrin
FE and Atelvia, Actavis may be the first and only generic competitor to
Warner Chilcott's branded products for a significant period absent the
Proposed Acquisition. By eliminating this potential competition between
Warner Chilcott and Actavis in each of these markets, the Proposed
Acquisition would harm U.S. consumers by substantially increasing the
likelihood of higher post-acquisition prices for Lo Loestrin FE and
Atelvia.
The Proposed Consent Agreement
The proposed Consent Agreement effectively remedies the Proposed
Acquisition's anticompetitive effects in the relevant markets by
requiring Actavis to divest to Amneal certain rights and assets related
to generic Femcon FE, generic Loestrin 24 FE, generic Lo Loestrin FE,
and generic Atelvia no later than ten days after consummating the
acquisition. In addition, the Consent Agreement requires Actavis to
enter into a supply agreement to provide Amneal with generic versions
of the Femcon FE and Loestrin 24 FE products to sell in the United
States for up to four years. Amneal is a New Jersey-based generic
pharmaceutical company that currently markets 65 products and maintains
an active product development pipeline. With its experience in generic
markets, Amneal is well positioned to replicate the competition that
would otherwise be lost as a result of the Proposed Acquisition.
If the Commission determines that Amneal is not an acceptable
acquirer of the assets to be divested, or that the manner of the
divestitures is not acceptable, Actavis must unwind the sale to Amneal
and divest the products within six months of the date the Order becomes
final, to a Commission-approved acquirer. If Actavis fails to divest
the products as required, the Commission may appoint a trustee to
divest the products.
The proposed Consent Agreement contains several provisions to help
ensure that the divestitures are successful. The Order requires Actavis
to maintain the economic viability, marketability, and competitiveness
of the divestiture products until such time as they are transferred to
Amneal or another Commission-approved acquirer. Actavis must also
transfer the manufacturing technology for the divestiture products to
Amneal and supply Amneal with the generic Femcon FE and Loestrin 24 FE
products during the transition period. In addition, the Consent
Agreement requires Actavis to relinquish any claim to marketing
exclusivity for generic Lo Loestrin FE and Atelvia products to ensure
that the incentives of the companies currently leading the patent
litigations relating to those products do not change.
The purpose of this analysis is to facilitate public comment on the
proposed Consent Agreement, and it is not intended to constitute an
official interpretation of the proposed Order or to modify its terms in
any way.
By direction of the Commission.
Donald S. Clark
Secretary.
[FR Doc. 2013-25847 Filed 10-30-13; 8:45 am]
BILLING CODE 6750-01-P