Indivior (INDV) 20FR12B/A Initial registration of securities (foreign private issuers) (amended)

Exhibit 4.25

Execution Version

IN THE UNITED STATES DISTRICT COURT

FOR THE EASTERN DISTRICT OF PENNSYLVANIA

IN RE SUBOXONE (BUPRENORPHINE HYDROCHLORIDE AND NALOXONE) ANTITRUST LITIGATION	MDL No. 2445
	Master File No. 2:13-MD-2445-MSG
THIS DOCUMENT RELATES TO:
	Case No. 2:16-cv-5073-MSG
Wisconsin, et. al. v. Indivior Inc. et. al.
STATE OF WISCONSIN et. al.
Plaintiffs,	Civ. A. No. 16-cv-5073
v.
Indivior Inc. f/k/a Reckitt Benckiser Pharmaceuticals, Inc., et. al.
Defendants.

[PROPOSED] STIPULATED FINAL JUDGMENT

AND DISMISSAL WITH PREJUDICE

Plaintiff States filed their Complaint in this matter pursuant to 15 U.S.C. §§ 1 and 2, 15 U.S.C. § 26 and their respective state laws. The Plaintiff States and Defendant Indivior Inc., by their respective attorneys, have reached an agreement to resolve this case through settlement, and without trial or final adjudication of any issue of fact or law, and stipulate to entry of this Stipulated Final Judgment and Dismissal with Prejudice (“Order”) to resolve all matters in dispute in this Action.

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FINDINGS

1.    The Court has jurisdiction over the subject matter and the parties to this Action for the purpose of entering into and enforcing this Order. Jurisdiction is retained by this Court for the purpose of enabling the Plaintiff States or Indivior to enforce this Order.

2.    Venue for this matter is proper in this Court under 15 U.S.C. § 22 and 28 U.S.C. § 139l(b) and (c).

3.    The Complaint alleges that Indivior engaged in violations of the Sherman Act and violations of the laws of the Plaintiff States, by engaging in anticompetitive activities designed to impede competition from generic equivalents of the brand-name drug Suboxone. Indivior disputes these allegations.

4.    This Order does not constitute any evidence against Indivior, or an admission of liability or wrongdoing by Indivior in this case or in other litigation. Rather, the terms of this Order reflect a negotiated compromise, entered into as a means to resolve contested issues without the burdens of litigation. This Order shall not be used in any way, as evidence or otherwise, in any other litigation or proceeding; provided that, nothing in this provision prevents the Plaintiff States or Indivior from using this Order in any proceeding regarding enforcement of this Order or as otherwise required by law.

5.    Entry of this Order is in the public interest.

STIPULATIONS

1.    Indivior and Plaintiff States, by and through their counsel, have agreed that entry of this Order fully and finally resolves the Released Claims, including all issues between the

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parties arising from the specific events giving rise to the allegations described in the Complaint, and precludes further litigation between Plaintiff States and Indivior regarding the Released Claims, except for the purposes of enforcing this Order.

2.    Indivior admits the facts necessary to establish personal and subject matter jurisdiction of this Court in this matter.

3.    Indivior denies the charges in the Complaint and disputes that the Plaintiff States are entitled to obtain relief.

4.    Indivior and Plaintiff States stipulate that they shall comply with the provisions of this Order pending its entry by the Court.

5.    Indivior and Plaintiff States stipulate that they will bear their own costs in this matter and shall not make any claims against the other party for attorney's fees or costs.

6.    Indivior and Plaintiff States waive all rights to appeal or otherwise challenge or contest the validity of this Order.

7.    The obligations set out below relate solely to business operations within the Plaintiff States.

DEFINITIONS

1.    “505(b)(2) Application” means an application filed with the United States Food and Drug Administration pursuant to Section 505(b)(2) of the Federal Food, Drug and Cosmetic Act, 21 U.S.C. § 355(b)(2).

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2.    “Action” means Civil Action Number 2:16-CV-5073 (MSG), consolidated into MDL No. 13-MD-2445 in the United States District Court for the Eastern District of Pennsylvania.

3.    “ANDA” means Abbreviated New Drug Application filed with the United States Food and Drug Administration pursuant to Section 505(j) of the Federal Food, Drug and Cosmetic Act, 21 U.S.C. § 355(j).

4.    “Authorized Generic” means a Drug Product that is manufactured pursuant to an NDA and Marketed in the United States under a name other than the proprietary name identified in the NDA.

5.    “Citizen Petition” means a public request that the FDA issue, amend, or revoke a regulation or order or take or refrain from taking any other form of administrative action pursuant to 21 C.F.R. § 10.30.

6.    “Commerce” has the same definition it has in 15 U.S.C. § 44.

7.    “Complaint” means any complaint filed by the Plaintiff States in Civil Action Number 2:16-CV-5073 (MSG), consolidated into MDL No. 13-MD-2445 in the United States District Court for the Eastern District of Pennsylvania, including but not limited to the First Amended Complaint.

8.    “Control” or “Controlled” means the holding of more than 50% of the common voting stock or ordinary shares in, or the right to appoint more than 50% of the directors of, or any other arrangement resulting in the right to direct the management of, the said corporation, company, partnership, joint venture, or entity.

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9.    “Direct Cost” means the variable costs incurred to produce or sell an Original Drug Product or Follow-on Drug Product, including the costs of ingredients and manufacturing, as well as the costs of marketing that product. The term Direct Cost does not include any allocation of overhead costs, administrative costs, research and development costs, or any other fixed costs.

10.    “Drug Product” means a finished dosage form (e.g., tablet, capsule, solution, or patch) as defined in 21 C.F.R. § 314.3(b), approved under a single NDA, ANDA, or 505(b)(2) Application, and available by prescription, that contains a drug substance, generally, but not necessarily, in association with one or more other ingredients. Notwithstanding the foregoing, the term Drug Product, as used in this Order, shall not include products that are predominantly purchased over-the-counter ("OTC") in the United States.

11.    “Effective Date” means the day that this Order is entered by the Court.

12.    “Effective Price” means the net price paid by a payor for a Drug Product, taking into account all discounts, refunds, reimbursements, and rebates.

13.    “FDA” means the U.S. Food and Drug Administration.

14.    “Follow-on Drug Product” means a Drug Product a) for which Indivior has submitted an NDA, controls an approved NDA, or has the right to distribute in the United States; b) that contains an active ingredient that is (i) the same as an active ingredient in a previously approved Original Drug Product, or (ii) an isomer, salt form variant, or metabolite of an active ingredient in a previously approved Original Drug Product; and c) that treats the same condition or targets the same patient population as the previously approved Original Drug Product.

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Notwithstanding the foregoing, for purposes of this Order, the term Follow-on Drug Product shall not include an Authorized Generic version of the Original Drug Product.

15.    “Indivior” means Defendant Indivior Inc.

16.    “Liaison States” means the States of Wisconsin and the State of Utah. All documentation provided to liaison states should be addressed to:

State of Wisconsin- Office of the Attorney General

Attn: Public Protection Unit (Antitrust)

17 W. Main St.

Madison, WI

Gwendolyn.Cooley@wisconsin.gov

And

State of Utah- Office of the Attorney General

Attn: Antitrust and Data Privacy Section

160 E 300 S, 5thFloor

PO BOX 140830

Salt Lake City, UT 84114-0830

dsonnenreich@agutah.gov

mwmartin@agutah.gov

17.    “Market,” “Marketed,” or “Marketing” means the promotion, offering for sale, sale, or distribution of a Drug Product.

18.    “Monetary Payment” means the amount that Indivior will pay the States via the method specified in Section III, “MONETARY PAYMENT”.

19.    “NDA” means a New Drug Application filed with the United States Food and Drug Administration pursuant to Section 505(b) of the Federal Food, Drug and Cosmetic Act, 21 U.S.C. § 355(b), including all changes or supplements thereto that do not result in the submission of a new NDA.

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20.    “Opioids Litigation” means any claims or potential claims related to the subject matter of In Re: National Prescription Opiate Litigation, Case No. 1:17-md-2804, MDL 2804 (Northern District of Ohio), in that or any other venue.

21.    “Original Drug Product” means a Drug Product that is Marketed in the United States and for which Indivior controls the NDA or has the right to distribute in the United States.

22.    “Released Claims” means any and all civil or administrative causes of action or claims whatsoever, in law or equity, that the Plaintiff States had as of the date of the Order, that were or could have been raised in this Action under any statute or common law, related to the facts alleged in the Complaint or alleged anticompetitive conduct related to Suboxone Film, including but not limited to claims for injunctive relief, damages, disgorgement, civil penalties, legal fees, and costs; provided, however that “Released Claims” do not include: (i) claims alleging a violation of this Order; (ii) Opioid Litigation claims; (iii) environmental claims; (iv) claims of political subdivisions to the extent that the Plaintiff States lack legal authority to release such claims; and (v) claims related to any potential tax liability. Nothing in this Order, however, shall be construed to waive or otherwise limit Indivior’s arguments or defenses regarding claims released by the Plaintiff States in other agreements, including but not limited to claims excluded from the definition of Released Claims.

23.    “Person” means any individual, partnership, joint venture, firm, corporation, association, trust, unincorporated organization, or other business, and any subsidiaries, divisions, groups, or affiliates thereof.

24.    “Plaintiff States” means the District, Commonwealth, or State of Wisconsin, Alabama, Alaska, Arkansas, California, Colorado, the District of Columbia, Connecticut,

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Delaware, Florida, Georgia, Hawaii, Idaho, Illinois, Iowa, Kansas, Kentucky, Louisiana, Maine, Maryland, Massachusetts, Michigan, Minnesota, Mississippi, Missouri, Nebraska, New Hampshire, New Mexico, New York, North Carolina, Ohio, Oklahoma, Oregon, Pennsylvania, Rhode Island, South Carolina, Tennessee, Utah, Vermont, Virginia, Washington, and West Virginia, who are Plaintiff States in Civ. A. No. 16-CV-5703 (Eastern District of Pennsylvania). Plaintiff States does not mean the Federal government or individual consumers.

25.    “Released Entities” means Indivior Inc., Indivior PLC, Indivior Solutions, and any joint venture, subsidiary, division, group, predecessor, successor, or affiliate that could be liable for any acts of the foregoing named entities, along with all directors, officers, employees, and agents of the same.

26.    “Status Quo Period” means a period beginning the day Indivior begins Marketing a Follow-on Drug Product in the United States and ends on the earlier of (i) six (6) months after a Third Party begins Marketing a Drug Product approved under an ANDA or 505(b )(2) Application for which the Original Drug Product is the reference listed drug, or (ii) three (3) years after the day Indivior or a licensee of Indivior begins Marketing the Follow-on Drug Product in the United States.

27.    “Third Party” means any Person other than Plaintiff States or Indivior.

I.    PROHIBITED ACTIVITY: CITIZEN PETITION PROCESS

If Indivior files a Citizen Petition, Indivior shall simultaneously disclose such filing to both the FDA and the Liaison States:

A.    All studies and data on which the Citizen Petition relies; and

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B.    All studies and data within the knowledge or possession of Indivior that address the validity or strength of one or more of the material contentions in the Citizen Petition.

II.    PROHIBITED ACTIVITY: PRODUCT SWITCHING CONDUCT

A.    Indivior shall provide a notification to the Liaison States thirty (30) calendar days after Indivior files an NDA for a Follow-on Drug Product in the United States. This notification shall include, inter alia, the following information: (i) a reference to this Order, (ii) the NDA number for the Follow-on Drug Product, and (iii) the associated Original Drug Product and NDA number under which it was approved.

B.    Indivior shall provide a second notification to the Liaison States six (6) months before the date specified for FDA approval of the Follow-on Drug Product under the Prescription Drug User Fee Act. This notification shall reference this Order and the previous notification submitted as required in the above Section II.A for the Follow-on Drug Product. Indivior shall submit the following documents and information with the notification:

1.    Documents sufficient to show the company’s pricing plans for the Original Drug Product and Follow-on Drug Product;

2.    Documents sufficient to show the forecasted sales for the Original Drug Product and Follow-on Drug Product;

3.    Transcripts of any of the Indivior’s investor calls during the prior twelve months that discuss the Follow-on Drug Product;

4.    A statement of all claimed benefits of the Follow-on Drug Product compared to the Original Drug Product; and

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5.    A statement of whether Indivior intends to materially alter the terms on which it sells the Original Drug Product, and, if so, identification of these terms, and all reasons for materially altering them.

C.    If, on the date when Indivior or its licensee begins Marketing a Follow-on Drug Product in the United States, a Third Party has submitted an ANDA or 505(b)(2) Application for which the Original Drug Product is the reference listed drug, then during the Status Quo Period, Indivior shall be prohibited from:

1.    Destroying inventory or withdrawing from the market any strength or formulation of the associated Original Drug Product; provided, however, Indivior may destroy Drug Product that has passed its Saleable Expiration Date.

2.    Failing to fill orders for the Original Drug Product on the same terms and conditions (except for those terms and conditions relating to Effective Price, which are addressed below in Section II.C.3) within the same time frame and with the same convenience as are orders for the Follow-on Drug Product. For the avoidance of doubt, this clause does not prohibit Indivior from offering different terms or conditions for a given Original Drug

Product or Follow-on Drug Product to different customers, so long as each customer is offered the same terms and conditions for the Original Drug Product as for the Follow-on Drug Product.

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3.    Offering an Effective Price for the associated Original Drug Product to any Customer that is higher than the Effective Price Indivior offers to that Customer for the Follow-on Drug Product;

Provided, however, this prohibition does not apply (a) if the Effective Price of the Original Drug Product is not increased by more than the corresponding increase in the prescription drug price component of the Consumer Price Index at any time during the eighteen (18) months prior to introduction of the Follow-on Drug Product or during the Status Quo Period; or (b) if the difference in Effective Price is attributable solely to a difference in the Direct Costs of the products.

4.    Deleting the National Drug Code for the associated Original Drug Product from the National Drug Data File;

Provided, however, that Indivior shall have no obligations under Section II.C with respect to an Original Drug Product: (a) for which the associated Follow-on Drug is no longer Marketed in the United States, or (b) that the FDA has determined should no longer be Marketed in the United States because of safety concerns. Indivior may recall and destroy products consistent with 21 C.F.R. Part 7, Subpart C; may take reasonable steps to protect safety in the event of manufacturing defects; and may take any action that is requested by FDA;

Provided further, for clarity, this Section II.C does not apply to Sublocade because any relevant Status Quo Period with respect to that Drug Product has ended.

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III.    MONETARY PAYMENT

Indivior will pay to the Plaintiff States a Monetary Payment in the amount of $102,500,000 (One Hundred Two Million, Five Hundred Thousand Dollars) before the latter of (i) thirty (30) days after the Effective Date or (ii) ten (10) days after receiving complete wire instructions and any related verifications from the Plaintiff States. Such payment shall be made via electronic deposit to the State of Maine, who will distribute such funds to the Plaintiff States. Such Monetary Payment is provided for the purpose of settlement only, and constitutes neither a penalty nor a fine. The payment may be used for any one or more of the following purposes, by the Attorneys General as they, in their sole discretion, see fit:

A.    payment of attorneys’ fees and expenses;

B.    antitrust or consumer protection law enforcement;

C.    for deposit into a state antitrust or consumer protection account (e.g., revolving account, trust account), for use in accordance with the state laws governing that account;

D.    for deposit into a fund exclusively dedicated to assisting state attorneys general enforce the antitrust laws by defraying the costs of a) experts, economists, and consultants in multistate antitrust investigations and litigation, b) training or continuing education in antitrust for attorneys in state attorney general offices, or c) information management systems used in multistate antitrust investigations and litigation; or

E.    for any other purpose as the attorneys general deem appropriate, consistent with the various states’ laws.

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Plaintiff States agree to notify Indivior of the amount of any Monetary Payment paid to class members in MDL No. 13-MD-2445 in the United States District Court for the Eastern District of Pennsylvania, if any.

IV.    NOTIFICATION REQUIREMENT

Indivior shall notify the Liaison States within 30 calendar days of starting to Market, either directly or through a licensee, Drug Products in the United States by:

A.    Receiving FDA approval to Market a Drug Product in the United States;

B.    Acquiring Control of a Person that has FDA approval to Market a Drug Product in the United States; or

C.    Acquiring or licensing a Drug Product that, at the time of such acquisition, has FDA approval to be Marketed in the United States.

V.    REPORTING REQUIREMENTS

Indivior shall submit to the Liaison States all reports required under Section V of the Stipulated Order for Permanent Injunction and Equitable Monetary Relief (ECF No. 5) entered in Federal Trade Commission v. Indivior Inc., 1:20-cv-00036-JPJ-PMS (W.D. Va.).

VI.    CHANGE OF CORPORATE CONTROL

A.    Indivior shall notify Liaison States at least 30 calendar days prior to:

1.    Any proposed dissolution of Indivior;

2.    Any proposed acquisition, merger, or consolidation of Indivior; or

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3.    Any other change in Indivior, including, but not limited to, assignment and the creation, sale or dissolution of subsidiaries, if such change might affect the compliance obligations arising out of this Order.

B.    No information or documents obtained by the means provided in Section VI shall be divulged by the Plaintiff States to any person other than an authorized representative of the Plaintiff States, except in the course of a legal proceeding regarding enforcement of this Order, or as otherwise required by law.

C.    If any Plaintiff State receives a request to divulge information provided by Indivior under Section VI.A to any person other than an authorized representative of the Plaintiff States (whether pursuant to a Freedom of Information Act, a Sunshine law, a subpoena, or otherwise), the Plaintiff State shall notify Indivior of this request as soon as practicable, consistent with the shorter of 21 days’ notice or the notice provided by state law, before any such disclosure is made.

VII.    ACCESS TO INFORMATION

A.    For the purpose of determining or securing compliance with this Order and subject to any legally recognized privilege or any applicable privacy laws and regulations, Indivior shall, upon reasonable notice and in response to a written request by any of the Plaintiff States:

1.    Provide the requesting Plaintiff State with documents and other electronically-stored information in Indivior's possession, custody, or control, that are relevant to compliance under the Order; and

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2.    Permit the requesting Plaintiff State to interview officers, directors, or employees of Indivior, who may have counsel (representing the Indivior, the individual, or both) present, regarding matters that are relevant to compliance under the Order.

B.    No information or documents obtained by the means provided in this Section VII shall be divulged by the Plaintiff States to any person other than an authorized representative of the Plaintiff States, except in the course of a legal proceeding regarding enforcement of the Order, or as otherwise required by law.

C.    If any Plaintiff State receives a request to divulge information provided by Indivior under Section VII.A to any person other than an authorized representative of the Plaintiff States (whether pursuant to a Freedom of Information Act, a Sunshine law, a subpoena, or otherwise), the Plaintiff State shall notify Indivior of this request as soon as practicable, consistent with the shorter of 21 days’ notice or the notice provided by state law, before any such disclosure is made.

VIII.    RETENTION OF JURISDICTION

This Court shall retain jurisdiction of this matter for purposes of enforcing this Order. Should a Plaintiff State or Indivior have a reasonable basis to believe that a party has engaged in a practice that violates a provision of this Order subsequent to the Effective Date, then such Plaintiff State or Indivior shall notify the party in writing of the specific objection, identify with particularity the provision of this Order that the practice appears to violate, and give the party thirty (30) days to respond to the notification before seeking relief from this Court.

IX.    EXPIRATION OF THE ORDER

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Unless otherwise specified in this Order, Sections I, II, IV, V, VI, and VII of this Order shall expire upon expiration of the Stipulated Order for Permanent Injunction and Equitable Monetary Relief (ECF No. 5) entered in Federal Trade Commission v. Indivior Inc., 1:20-cv-00036-JPJ-PMS (W.D. Va.).

X.    DISMISSAL AND RELEASE OF CLAIMS

This Action and Complaint are hereby dismissed with prejudice and each party shall bear its own costs.

In exchange for the Monetary Payment and agreement to abide by the terms contained in this Order, the Plaintiff States hereby fully and forever release and discharge the Released Entities from the Released Claims.

This Order and legal process to enforce the terms of this Order shall provide the sole and exclusive remedy for any and all Released Claims, and the Plaintiff States shall be forever barred from initiating, asserting, maintaining, or prosecuting any and all Released Claims against Indivior. Plaintiff States expressly waive, solely with respect to the Released Claims, any and all rights and benefits conferred by Section 1542 of the California Civil Code or similar state laws. Plaintiff States may hereafter discover facts other than or different from those which it knows or believes to be true with respect to the Released Claims, but Plaintiff States hereby expressly release any known or unknown, foreseen or unforeseen, suspected or unsuspected, contingent or non-contingent Released Claims, whether or not concealed or hidden, without regard to the subsequent discovery or existence of such different or additional facts.

XI.    ADDITIONAL PROVISIONS

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A.    All required notices to the Liaison States under this Order may be made by electronic mail to the addresses set forth in the definition of Liaison States. All required notices to Indivior under this Order shall be made by both regular and electronic mail to the following addresses:

Indivior, Inc.

Attn: Chief Legal Officer

10710 Midlothian Tpke

Suite 125

North Chesterfield, VA 23235

Legal@indivior.com

Both the Plaintiff States and Indivior may change the addresses for notice by providing written notice of the updated addresses to the other party.

B.    This Order may be modified or amended only by a written stipulation of the Parties as approved by the Court.

C.    Indivior shall not knowingly cause a third party to engage in practices prohibited by this Order on its behalf.

D.    Any failure by any party to this Order to insist upon the strict performance by any other party of any of the provisions of this Order shall not be deemed a waiver of any of the provisions of this Order, and such party, notwithstanding such failure, shall have the right thereafter to insist upon the specific performance of any and all of the provisions of this Order.

E.    This Order represents the full and complete terms of the settlement entered into by the Parties hereto. In any action undertaken by the Parties, no prior versions of this Order and no prior versions of any of its terms that were not entered by the Court in this Order, may be introduced for any purpose whatsoever.

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F.    This Order may be executed in counterparts, and an electronic signature shall be deemed to be, and shall have the same force and effect as, an original signature.

[PROPOSED] ORDER

And now on this [______] day of June 2023, pursuant to and upon consideration of the Stipulated Final Judgment and Dismissal with Prejudice is APPROVED and SO ORDERED.

It is further ORDERED that having resolved all claims against the last remaining Defendant and pursuant to the provisions of Rule 41.1(b) of the Local Rules of Civil Procedure, the above action is DISMISSED with prejudice, without costs.

BY THE COURT:

Judge Mitchell S. Goldberg

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FOR INDIVIOR INC.	FOR THE STATE OF WISCONSIN JOSHUA L. KAUL ATTORNEY GENERAL
/s/ Jeff Burris	By:	/s/ Gwendolyn J. Lindsay Cooley
Jeff Burris	Gwendolyn J. Lindsay Cooley
Director and Secretary	Assistant Attorney General
10710 Midlothian Tpke	17 W. Main St
Suite 125	PO Box 7857
North Chesterfield, VA 23235	Madison, WI 53707-7857

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Wisconsin v. Indivior, Case No. 16-CV-5073
May 26, 2023
STATE OF ALABAMA
STEVE MARSHALL, ATTORNEY GENERAL
By:	/s/ Olivia W. Martin
Olivia W. Martin
Assistant Attorney General
Alabama Office of the Attorney General
501 Washington Ave., Montgomery, AL 36103

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Wisconsin v. Indivior, Case No. 16-CV-5073
May 31, 2023
STATE OF ALASKA
TREG TAYLOR, ATTORNEY GENERAL
By:	/s/ Ian Engelbeck
Ian R. Engelbeck
Assistant Attorney General
Alaska Department of Law
Special Litigation Section
1031 West 4th Ave., Suite 200
Anchorage, AK 99501
Attorney for Plaintiff State of Alaska

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FOR PLAINTIFF STATE OF ARKANSAS:

TIM GRIFFIN

ATTORNEY GENERAL

/s/ Amanda J. Wentz

AMANDA J. WENTZ

Ark. Bar No. 2021066

Assistant Attorney General

Office of the Arkansas Attorney General

323 Center Street, Suite 200

Little Rock, AR 72201

(501) 682-1178

Amanda.Wentz@ArkansasAG.gov

Attorney for Plaintiff State of Arkansas

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ROB BONTA

Attorney General of California

PAULA BLIZZARD

Senior Assistant Attorney General

/s/ Quyen D. Toland

QUYEN D. TOLAND

Deputy Attorney General

Office of the Attorney General

455 Golden Gate Ave., Suite 11000

San Francisco, CA 94102-7004

Tel.: (415) 510-3534

E-mail: Quyen.Toland@doj.ca.gov

Attorneys for Plaintiff State of California

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FOR PLAINTIFF STATE OF COLORADO:

PHILIP J. WEISER

ATTORNEY GENERAL

/s/ Carla J. Baumel

Carla J. Baumel

Assistant Attorney General

Consumer Protection Section

Colorado Department of Law

Ralph L. Carr Colorado Judicial Center

1300 Broadway, 7th Floor

Denver, CO 80203

Email: Carla.Baumel@coag.gov

Telephone: (720) 508-6235

Attorneys for Plaintiff State of Colorado

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FOR PLAINTIFF STATE OF CONNECTICUT

WILLIAM TONG

ATTORNEY GENERAL

/s/ Nicole Demers

Nicole Demers

Deputy Associate Attorney General

Antitrust Section

Connecticut Office of the Attorney General

165 Capitol Ave.

Hartford, CT 06106

Tel.: (860) 808-5030

nicole.demers@ct.gov

Attorneys for Plaintiff State of Connecticut

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Wisconsin v. Indivior, Case No. 16-CV-5073
May 31, 2023
STATE OF DELAWARE
KATHLEEN JENNINGS, ATTORNEY GENERAL
By:	/s/ Michael A. Undorf
Michael A. Undorf
Deputy Attorney General
Delaware Department of Justice
820 N. French St., 5th Floor
Wilmington, DE 19801
(302) 683-8816
Michael.Undorf@delaware.gov
Attorney for Plaintiff State of Delaware

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FOR THE PLAINTIFF STATE THE DISTRICT OF COLUMBIA:

BRIAN L. SCHWALB

ATTORNEY GENERAL

JENNIFER C. JONES

Deputy Attorney General

Public Advocacy Division

BETH MELLEN

WILLIAM F. STEPHENS

Assistant Deputy Attorneys General

Public Advocacy Division

/s/Adam Gitlin

ADAM GITLIN [90004308]

Chief, Antitrust and Nonprofit Enforcement Section

Public Advocacy Division

ELIZABETH G. ARTHUR [1531185]

Assistant Attorneys General

Public Advocacy Division

400 6th Street NW, 10th Floor

Washington, D.C. 20001

Tel.: 202-442-9864

Attorneys for Plaintiff State the District of Columbia

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Wisconsin v. Indivior, Case No. 16-CV-5073
May 31, 2023
STATE OF FLORIDA
ASHLEY MOODY, ATTORNEY GENERAL
By:	/s/ Nicholas J. Weilhammer
Nicholas J. Weilhammer (FL Bar No. 479322)
Associate Deputy Attorney General for Enforcement
Lizabeth A. Brady (FL Bar No. 457991)
Director of Antitrust Enforcement
R. Scott Palmer (FL Bar No. 220353)
Special Counsel for Antitrust Enforcement
Rachel S. Brackett (FL Bar No. 109775)
Assistant Attorney General
Florida Office of the Attorney General
Antitrust Division
PL-01, The Capitol
Tallahassee, FL 32399
Telephone: (850) 414-3300
Fax: (850) 488-9134
Email: Nicholas.weilhammer@myfloridalegal.com
Attorneys for the Plaintiff State of Florida

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FOR PLAINTIFF STATE OF GEORGIA
/s/ Charles Thimmesch
Christopher M. Carr	112505
Attorney General
Margaret K. Eckrote	238709
Deputy Attorney General
Jeffrey W. Stump	690425
Senior Assistant Attorney General
Charles Thimmesch	322197
Assistant Attorney General
Office of the Attorney General
40 Capitol Square, SW
Atlanta, Georgia 30334
(404) 458-3626
cthimmesch@law.ga.gov
Counsel for Georgia

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Wisconsin v. Indivior, Case No. 16-CV-5073
May 31, 2023
STATE OF HAWAII
ANNE E. LOPEZ, ATTORNEY GENERAL
By:	/s/ Rodney I. Kimura.
Rodney I. Kimura
Deputy Attorney General
Department of the Attorney General
State of Hawaii
425 Queen Street
Honolulu, HI. 96813
Attorneys for Plaintiff State of Hawaii

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FOR PLAINTIFF STATE OF IDAHO:

RAÚL R. LABRADOR

ATTORNEY GENERAL

/s/ John K. Olson

John K. Olson, Acting Division Chief

Consumer Protection Division

Office of the Attorney General

954 W. Jefferson Street, 2nd Floor

P.O. Box 83720

Boise, Idaho 83720-0010

Telephone: (208) 334-2424

john.olson@ag.idaho.gov

Attorneys for Plaintiff State of Idaho

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FOR PLAINTIFF STATE OF ILLINOIS
KWAME RAOUL
ATTORNEY GENERAL
By:	/s/ Elizabeth L. Maxeiner
Elizabeth L. Maxeiner
Chief, Antitrust Bureau
Office of the Illinois Attorney General
100 W. Randolph St. 11th Fl.
Chicago, Illinois 60601
Elizabeth.maxeiner@ilag.gov
Attorneys for Plaintiff State of Illinois

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FOR PLAINTIFF STATE OF IOWA:

BRENNA BIRD

ATTORNEY GENERAL

/s/ Noah Goerlitz

Noah Goerlitz

Assistant Attorney General

Office of the Iowa Attorney General

1305 E. Walnut St.

Des Moines, IA 50319

Telephone: (515) 725-1018

noah.goerlitz@ag.iowa.gov

Attorney for Plaintiff State of Iowa

33

FOR PLAINTIFF STATE OF KANSAS:

KRIS W. KOBACH

ATTORNEY GENERAL

/s/ Lynette R. Bakker

Lynette R. Bakker

First Assistant Attorney General

Antitrust & Business Organizations

Public Protection Division

Office of the Kansas Attorney General

120 S.W. 10th Avenue, 2nd Floor

Topeka, KS 66612-1597

Telephone: (785) 296-3751

Fax: (785-291-3699

Email: lynette.bakker@ag.ks.gov

Attorneys for Plaintiff State of Kansas

34

Office of the Attorney General of Kentucky

s/ Jonathan E. Farmer

Jonathan E. Farmer

Deputy Executive Director of Consumer Protection

Office of the Attorney General of Kentucky

1024 Capital Center Drive, Suite 200

Frankfort, KY 40601

Tel: 502-696-5448

Fax: 502-573-8317

Jonathan.Farmer@ky.gov

ATTORNEY FOR THE STATE OF KENTUCKY

35

Respectfully submitted,
	JEFF LANDRY
	ATTORNEY GENERAL
	Attorney General of Louisiana
	By:	/s/ Christopher J. Alderman
	Christopher J. Alderman (LA #38652)
	Section Chief, Assistant Attorney General
	Public Protection Division, Complex Litigation Unit
	1885 N. 3rd St., 4th Floor.
	Baton Rouge, LA 70802
	Tel: 225.326.6400
	Fax: 225.326.6499
			AldermanC@ag.Louisiana.gov

36

FOR PLAINTIFF STATE OF MAINE:

AARON M. FREY

ATTORNEY GENERAL

/s/ Christina M. Moylan

Christina M. Moylan, AAG

Chief, Consumer Protection Division

Office of the Attorney General

6 State House Station

Augusta, Maine 04333-0006

Telephone: (207) 626-8800

christina.moylan@maine.gov

Attorneys for Plaintiff Stale of Maine

37

Wisconsin v. Indivior, Case No. 16-CV-5073
May 31, 2023
STATE OF MARYLAND
ANTHONY G. BROWN, ATTORNEY GENERAL
By:	/s/Schonette J. Walker
Schonette J. Walker
Assistant Attorney General
Chief, Antitrust Division
Gary Honick
Assistant Attorney General
Deputy Chief, Antitrust Division
Byron Warren
Assistant Attorney General
Office of the Maryland Attorney General
200 St. Paul Place
Baltimore, MD 21202

38

FOR PLANTIFF COMMONWEALTH OF MASSACHUSETTS:

ANDREA JOY CAMPBELL

Attorney General

 /s/ William T. Matlack

WILLIAM T. MATLACK (MA BBO No. 552109)

Assistant Attorney General, Chief, Antitrust Division

Office of the Attorney General One

Ashburton Place, 18th Floor Boston,

MA 02108

Tel: (617) 727-2200

Email: William.Matlack@mass.gov

39

FOR THE PLAINTIFF STATE OF MICHIGAN:

DANA NESSEL

ATTORNEY GENERAL

/s/ Carl J. Hammaker

Carl J. Hammaker (P81203)

Darrin F. Fowler (P53464)

Assistant Attorneys General

Michigan Dep’t of Attorney General

Corporate Oversight Division

P.O. Box 30736

Lansing, MI 48909

Email: HammakerC@michigan.gov

Telephone: (517) 335-7632

Attorneys for Plaintiff State of Michigan

40

May 31, 2023

KEITH ELLISON

Attorney General

State of Minnesota

JESSICA WHITNEY

Deputy Attorney General

JAMES W. CANADAY

Deputy Attorney General

/s/ Justin Moor

JUSTIN MOOR

Assistant Attorney General

Atty. Reg. No. 0397596

445 Minnesota Street, Suite 1400

St. Paul, Minnesota 55101-2130

(651) 724-9627

justin.moor@ag.state.mn.us

ATTORNEYS FOR THE STATE OF MINNESOTA

41

FOR PLAINTIFF STATE OF MISSISSIPPI
LYNN FITCH, ATTORNEY GENERAL
STATE OF MISSISSIPPI
By:	/s/ Hart Martin
	Hart Martin (MSB # 106129)
	Deputy Director and Special Assistant Attorney General
	Consumer Protection Division
	Mississippi Attorney General’s Office
	Post Office Box 220
	Jackson, Mississippi 39205
	Telephone: 601-359-4223
	Fax: 601-359-4231
	Hart.martin@ago.ms.gov

42

FOR THE STATE OF MISSOURI
ANDREW BAILEY
ATTORNEY GENERAL
By:	/s/ Michael Schwalbert
Michael Schwalbert
Assistant Attorney General
Consumer Protection Section
Missouri Attorney General's Office
815 Olive Street | Suite 200
Saint Louis, Missouri 63101
michael.schwalbert@ago,mo.gov
Phone: 314-340-7888
Fax: 314-340-7981

43

FOR PLAINTIFF STATE OF NEBRASKA

MICHAEL T. HILGERS

ATTORNEY GENERAL

/s/ Justin C. McCully

Justin C. McCully

Colin P. Snider

Assistant Attorney General

Consumer Protection Bureau

Nebraska Attorney General’s Office

2115 State Capitol

Lincoln, NE 68509-8920

Telephone: (402) 471-2682

Fax: (402) 471-4725

Justin.mccully@nebraska.gov

Colin.snider@nebraska.gov

Attorneys for Plaintiff State of Nebraska

44

FOR PLAINTIFF STATE OF NEW HAMPSHIRE:

JOHN T. FORMELLA

ATTORNEY GENERAL

/s/ Zachary Frish

Zachary A. Frish

Attorney

Consumer Protection & Antitrust Bureau

New Hampshire Department of Justice | Office of the Attorney General

33 Capitol Street

Concord, NH 03301

(603) 271-2150

zachary.a.frish@doj.nh.gov

Attorney for Plaintiff State of New Hampshire

45

FOR PLAINTIFF STATE OF NEW MEXICO:

RAÚL TORREZ

ATTORNEY GENERAL

/s/ Nicholas M. Sydow

Nicholas M. Sydow

Deputy Solicitor General

Office of the New Mexico Attorney General

408 Galisteo St.

Santa Fe, NM 87501

Telephone: (505) 490-4060

nsydow@nmag.gov

Attorneys for Plaintiff State of New Mexico

46

FOR THE STATE OF NEW YORK

LETITIA JAMES

ATTORNEY GENERAL

/s/ Elinor R. Hoffmann

Elinor R. Hoffmann

Chief, Antitrust Bureau

Amy McFarlane

Deputy Chief, Antitrust Bureau

Saami Zain, Assistant Attorney General

28 Liberty Street

New York, NY 10005

47

FOR PLAINTIFF STATE OF NORTH CAROLINA

JOSHUA H. STEIN

ATTORNEY GENERAL

/s/ Jessica V. Sutton

Jessica V. Sutton

Special Deputy Attorney General

Kimberley D’Arruda

Director, Technology, Healthcare, and Antitrust Section

Consumer Protection Division

North Carolina Department of Justice

P.O. Box 629

Raleigh, NC 27602

Tel.: (919) 716-0998

jsutton2@ncdoj.gov

Attorneys for Plaintiff State of North Carolina

48

FOR PLAINTIFF STATE OF OHIO:
DAVE YOST
ATTORNEY GENERAL
/s/ Beth A. Finnerty
Beth A. Finnerty
Section Chief, Antitrust Section
Office of the Ohio Attorney General
30 E. Broad St., 26th Floor
Columbus, OH 43215
Telephone: (614) 466-4328
Fax: (614) 995-0266
Email: Beth.Finnerty@OhioAGO.gov
Attorneys for Plaintiff State of Ohio
Date:	May 26, 2023

49

FOR PLAINTIFF STATE OF OKLAHOMA:

GENTNER DRUMMOND

ATTORNEY GENERAL

/s/ Caleb J. Smith

Caleb J. Smith, OBA No. 33613

Assistant Attorney General

Consumer Protection Unit

Office of the Oklahoma Attorney General

15 West 6th Street

Suite 1000

Tulsa, OK 74119

Tel. (918) 581-2230

Fax (918) 938-6348

Email: calebsmith@oag.ok.gov

Attorney for Plaintiff State of Oklahoma

50

/s/ Brian A. de Haan

Brian A. de Haan

Senior Assistant Attorney General

Civil Enforcement Division

Oregon Department of Justice

100 SW Market Street

Portland, OR 97201

Tel. (971) 673-1880

brian.a.dehaan@doj.state.or.us

51

FOR PLAINTIFF COMMONWEALTH OF PENNSYLVANIA:

MICHELLE A. HENRY

ATTORNEY GENERAL

/s/ Tracy W. Wertz

Tracy W. Wertz

Chief Deputy Attorney General

Antitrust Section

Pennsylvania Office of Attorney General

14th Floor Strawberry Square,

Harrisburg, PA 17120-1410

Telephone: (717) 787-4530

twertz@attorneygeneral.gov

Attorneys for Plaintiff Commonwealth of Pennsylvania

52

FOR PLAINTIFF STATE OF RHODE ISLAND:

PETER F. NERONHA

ATTORNEY GENERAL

/s/ Adam D. Roach

Adam D. Roach

Special Assistant Attorney General

State of Rhode Island | Office of the Attorney General

150 South Main Street

Providence, RI 02903

Email: aroach@riag.ri.gov

Telephone: (401) 274-4400 x 2490

Attorneys for Plaintiff State of Rhode Island

53

Wisconsin v. Indivior, Case No. 16-CV-5073
May 31, 2023
STATE OF SOUTH CAROLINA
ALAN WILSON, ATTORNEY GENERAL
By:	/s/ Clark Kirkland, Jr.
Clark Kirkland, Jr.
Assistant Attorney General
Office of the Attorney General
State of South Carolina
P.O. Box 11549
Columbia, SC 29211

54

FOR PLAINTIFF STATE OF TENNESSEE

JONATHAN SKRMETTI

ATTORNEY GENERAL

 /s/J. Tate Ball

J. Tate Ball

Assistant Attorney General

Consumer Protection Division

Office of the Tennessee Attorney General

P.O. Box 20207

Nashville, Tennessee 37202

Email: Tate.Ball@ag.tn.gov

Telephone: (615)741-8091

Attorneys for the Plaintiff State of Tennessee

55

Wisconsin v. Indivior, Case No. 16-CV-5073
May 31, 2023
STATE OF UTAH
SEAN D. REYES, ATTORNEY GENERAL
DAVID SONNENREICH
Deputy Attorney General
Antitrust and Data Privacy Section Director
By:	/s/ Marie W.L. Martin
Marie W.L. Martin
Assistant Attorney General
Utah Office of the Attorney General
Antitrust and Data Privacy Section
160 E 300 S, 5th Floor
P.O. Box 140830
Salt Lake City, UT 84114-0830
(801)366-0260
mwmartin@agutah.gov
Attorneys for Plaintiff State of Utah

56

FOR PLAINTIFF STATE OF VERMONT
CHARITY R. CLARK
ATTORNEY GENERAL
By:	/s/ Jill S. Abrams
Jill S. Abrams
Assistant Attorney General
Director, Consumer Protection and Antitrust Unit
109 State Street
Montpelier, VT 05609
Attorneys for Plaintiff State of Vermont

57

FOR PLAINTIFF COMMONWEALTH OF VIRGINIA
JASON S. MIYARES
ATTORNEY GENERAL
By:	/s/ Tyler T. Henry
Tyler T. Henry
Assistant Attorney General/Unit Manager
Antitrust Unit
Office of the Virginia Attorney General
202 North 9th Street
Richmond, Virginia 23219
THenry@oag.state.va.us
Attorneys for Plaintiff' Commonwealth of Virginia

58

FOR PLAINTIFF STATE OF WASHINGTON:

ROBERT W. FERGUSON

Attorney General

s/Luminita Nodit

LUMINITA NODIT

Lumi.Nodit@atg.wa.gov

Assistant Attorney General, Antitrust Division

Washington State Office of the Attorney General

800 Fifth Ave., Suite 2000

Seattle, WA 98104

Tel: (206) 254-0568

Attorneys for Plaintiff State of Washington

59

FOR PLAINTIFF STATE OF WEST VIRGINIA:

PATRICK MORRISEY

ATTORNEY GENERAL

/s/ Douglas L. Davis

Douglas L. Davis, Senior Assistant Attorney General

Consumer Protection and Antitrust Division

Office of the Attorney General

1900 Kanawha Boulevard East

Building 6, Suite 401

Charleston, WV 25305

Telephone: (304) 558-8986

douglas.l.davis@wvago.gov

Attorneys for Plaintiff State of West Virginia

60

CERTIFICATE OF SERVICE

I hereby certify that on June 1, 2023, I electronically filed the [Proposed] Stipulated Final Judgment and Dismissal with Prejudice using the Court’s CM/ECF system, which will automatically send email notification of such filing to all attorneys of record. Unredacted copies were sent to the Court via U.S. Mail and were served on all parties via electronic mail.

/s Gwendolyn J. Lindsay Cooley

GWENDOLYN J. COOLEY

Assistant Attorney General

State Bar #1053856

Wisconsin Department of Justice

Post Office Box 7857

Madison, Wisconsin 53707-7857

(608) 261-5810

(608) 266-2250 (Fax)

cooleygj@doj.state.wi.us

20