Post-Daimler Paradigm Shift: Personal Jurisdiction in the ANDA Context

Mylan recently filed two ANDAs seeking approval to sell generic versions of AstraZeneca’s ONGLYZA® and KOMBIGLYZE™ drug products.  In response, AstraZeneca LP (“AZP”) filed a complaint in the District of Delaware for patent infringement, and Mylan moved to dismiss for lack of personal jurisdiction.  Judge Gregory M. Sleet denied the motion, finding specific jurisdiction because…