The Antitrust Division of the Department of Justice (the “Division”) has announced a major policy shift. When a company has been convicted for a criminal antitrust offense, the Division may seek to impose the significant...more
On December 3, 2012, a divided Second Circuit held in United States v. Caronia (“Caronia”) that the misbranding provisions of the Federal Food, Drug, and Cosmetic Act (“FDCA”) do not criminalize “the truthful off-label...more