Motion to Dismiss - Sanofi, Chattem, and Quten Research

The documents below include a 37-page Motion to Dismiss filed by Sanofi-Aventis U.S. LLC, Chattem, Inc., and Quten Research Institute, LLC, along with sworn declarations from three senior executives submitted in support of that motion.

In this filing, the three companies ask the U.S. District Court to dismiss all claims against them. Their motion rests on two primary arguments.

First, they argue that the Court lacks personal jurisdiction over them. They state that none of the three companies is incorporated or headquartered in Oregon and that they do not have sufficient contacts with Oregon to justify being sued there. They assert that they did not employ Plaintiff, did not control DRVM LLC, did not participate in DRVM’s payroll or internal operations, and do not own DRVM or the related entities identified in the Complaint. Based on those assertions, they contend that exercising jurisdiction over them would violate constitutional due process principles.

Second, they argue that even if jurisdiction existed, the Complaint fails to state a legally sufficient claim against them. They maintain that the allegations of fraud, fraudulent concealment, civil conspiracy, alter ego liability, and successor liability are conclusory and unsupported by specific factual misconduct tied to these three companies. According to their motion, the dispute began as a wage issue involving DRVM LLC — which they describe as Plaintiff’s employer — and they argue that the Complaint improperly attempts to expand that dispute into broader allegations of corporate control and concealment without factual support.

The executive declarations submitted with the motion are intended to reinforce these arguments. Each executive declares under penalty of perjury that their company has no ownership interest in DRVM, no contractual relationship with DRVM or the related demo entities, no involvement in DRVM’s internal management, and no employment relationship with Plaintiff. The declarations also emphasize that each company is headquartered outside Oregon and operates nationally rather than through Oregon-specific operations.

I am posting these filings here so everyone can read exactly what was argued — in full context and without commentary. Transparency matters.

My Opposition will be filed next.