IN THE [OWA DISTRICT COURT FOR POLK COUNTY STATE OF IOWA ex rel. THOMAS J. MILLE ATTORNEY GENERAL OF [OWA Plaintiff, v EQUITY NO. EQCE, PURDUE PHARMA L.P., PURDUE PHARMA INC., THE PURDUE FREDERICK COMPANY, INC., PURDUE. PHARMA COMPANY, P2 LABORATORIES INC., and RICHARD S. SACKLER, PETITION Defendants, 1. INTRODUCTION This proceeding is brought by the State of fowa through its Attorney General, Thomas J. Miller, against Defendants Purdue Pharma LP., Purdue Pharma Ine, The Purdue Frederick Company, Ine., P.F. Laboratories Ine., and Purdue Pharma Company (collectively, “Purdue”) and Richard S. Sackler pursuant fo the fowa Consumer Fraud Act, Towa Code section 714.16, and he Older Iowans Law, Iowa Code section 714.16A. The lawsuit socks redress for Defendants’ false, deceptive, misleading, and omissive representations and unfair practices relared to the advertisement, marketing, promotion and sale of OxyContin in Towa, Since its debut in 1996, Purdue has aggressively marketed OxyContin, a powerful opioid painkiller that is twice as potent as morphine, to treat chronic pain that occurs asa result cof common conditions suchas low back pain and osteoarthritis, Oxycodone, the active ingredient in OxyContin, bas long been known to have addictive properties similar to morphine,Despite the serious risks attendant with OxyContin use, Purdue repeatedly made false and ‘deceptive claims ina myriad of forums and formats that OxyContin was safe and suitable fora wide range ofp patients because, ver alia, OxyCor posed a nearly nonexistent risk of eddition;itstime-conteo release formule was believed to rode the abuse ibility ‘of the drug; patent behaviors signaling addition wore in fact only “pseudoaddietion” indicating the need for mare opioids; long-term opioid use improved patients” quality of lite and function; ad that opioids were suitable for vulnerable groups, such as elderly patents and veteran. Purdue made deceive comparisons between OxyContin and other pain relievers thit implied that OxyContin was a safer altemative, and failed to disclose or understated the risks atlendant witht se Purdue knowingly nistepresented that OxyContin would provide 12 hours of pain ree, ‘hile it knew that many patients experienced only 8-9 hours of pain sli, resulting in dangerous “end of dose faire™ that can lead to misuse and addiction. When patients experienced less than twelve hours of pain elie, Purdue encourage health eare providers to preseriber higher, more dangerous doses of OxyContin. Purdue omitted or inersated important information about the risks of long tem opioid use, such asthe fact hat higher doses or longer use of opioids pose gestrrsks of adiction and overdose Purdue perpetuated its unlawful practices through broad, decp, and multifaceted marketing campaign that permeated all levels ofthe health care sytem in Towa, ‘They made individualized sales itches to Towa health care provides, developed and disseminated written materials and publications directed at prescribers and patients,sponsored pro-pain patient advocacy groups, co-opted medical education programs, and used numerous other means in order to increase sales oftheir opioids 9. Ase Pundue executive and Board member, Defendant Richard 8. Sackler was @ primary participant in Purdse’s false, deceptive, misleading, and omissive representations and unfair practices related to the advertisement, marketing, promotion and sale of OxyContin, in Jowa. In his own words, Sackler has admitted tha, “iJ is almost as if | dedicated my life" to making OxyContin a huge success. Through his actions and decisions, Sackler played a central roe in the unlawful conduct alleged in this Petition I PARTIES 10, PLAINTIFF, STATE OF IOWA brings this action through the office of the lova ‘Atorney General, Thomas J. Miller. The lowa Attorney General is expressly authorized to bring this action on behalf of the State of lowa pursuant to the lows Consumer Fraud ‘Act, Iowa Code sec. 714.16 et seq, (2018) and 714.16A (2018) for remedies inchuding but ‘not limited to permanent injunctive and other equitable relief, restitution, disgorgement, civil penalties, and attorney's fees and costs, DEFENDANT PURDUE PHARMA L.P, is a limited partnership established in Delaware with its principal place of business in Connecticut, whose general partner is Purdue Pharm Ine. 12, DEFENDANT PURDUE PHARMA INC. is « New York corporation with its principal place of business in Connecticut and isthe general partner of Purdue Pharma LP. 13, DEFENDANT THE PURDUE FREDERICK COMPANY INC. is a New York corporation with its principal place of business in Connecticut