More Comments
A little less than two weeks ago, we linked to public comments on the FTC’s study of authorized generics. Via the Orange Book Blog, the FTC has posted additional comments on its website. The new commentators are:
- Eli Lilly and Company
- IMS Health Incorporated
- AARP
- Gilberts LLP
- Actavis Group
- Pharmaceutical Research and Manufacturers of America - PhRMA
- Ronald Davis -on behalf of unnamed client
- Prasco, LLC
- Consumers Union
I have not had time to examine all of these additional comments. I will note that PhRMA’s, IMS’s, Actavis’, and Ron Davis’s comments all concern the information the FTC should (or should not) seek/request/subpoena. The Eli Lily comment is very interesting and substantive and I will have a separate post shortly on it.
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June 19th, 2006 at 3:43 pm
[…] As just mentioned, Eli Lily was one of the few commentators to comment on the substantive issues regarding the FTC’s “study of the use, and likely short- and long-term competitive effects, of authorized generics in the prescription drug marketplace.” The entire comment is worth reading but here is Lily on the long-term competitive effects of authorized generics: Questions about the long-term effects of authorized generics are sometimes stated as whether authorized generics might decrease the profitability of the 180-day exclusivity for the fist-filing generic. There are at least three assumptions implicit in this question that the Commission should scrutinize with the information it is collecting: […]