Pandemic Darlings The pandemic economy, in original documents
Home Court filings Apter v. Department of Health and Human Services Defendants’ Motion to Dismiss — Apter v. HHS

Court filing

Defendants’ Motion to Dismiss — Apter v. HHS

Filed August 26, 2022 in Apter v. Department of Health and Human Services; one of 66 filings from this case.

Record facts

CourtU.S. District Court for the Southern District of Texas, Galveston Division
Filed2022-08-26

U.S. District Court for the Southern District of Texas, Galveston Division · No. 3:22-cv-00184 · Doc. 25 · 2022-08-26 · Docket on CourtListener

Full text

UNITED STATES DISTRICT COURT 
FOR THE SOUTHERN DISTRICT OF TEXAS 
GALVESTON DIVISION 
 
 
ROBERT L. APTER, et al., 
 
 
 
 
 
Plaintiffs, 
 
 
v. 
 
U.S. DEPARTMENT OF HEALTH 
AND HUMAN SERVICES, et al., 
 
 
 
 
 
Defendants. 
 
 
Case No. 3:22-cv-184 
 
JUDGE JEFFREY V. BROWN 
Defendants’ Motion to Dismiss the Amended Complaint 
OF COUNSEL: 
 
SAMUEL R. BAGENSTOS 
General Counsel 
U.S. Department of Health and 
Human Services 
 
MARK RAZA 
Associate General Counsel 
Food and Drug Division 
U.S. Department of Health  
 and Human Services 
Chief Counsel 
Food and Drug Administration 
 
WENDY S. VICENTE 
Acting Deputy Chief Counsel, 
Litigation 
Food and Drug Administration 
 
LEAH A. EDELMAN 
BRIAN M. BOYNTON 
Principal Deputy Assistant Attorney 
 General 
 
ARUN G. RAO 
Deputy Assistant Attorney General 
  
GUSTAV W. EYLER 
Director 
 
HILARY K. PERKINS 
Assistant Director 
 
ISAAC C. BELFER 
Attorney-In-Charge  
D.C. Bar No. 1014909 
OLIVER MCDONALD 
Of Counsel  
N.Y. Bar No. 5416789 
Trial Attorneys 
Case 3:22-cv-00184   Document 25   Filed on 08/26/22 in TXSD   Page 1 of 41

 
 
 
 
Associate Chief Counsel 
Food and Drug Administration 
Consumer Protection Branch 
Civil Division  
U.S. Department of Justice 
P.O. Box 386 
Washington, DC  20044-0386 
(202) 305-7134 (Belfer) 
(202) 305-0168 (McDonald) 
(202) 514-8742 (fax) 
Isaac.C.Belfer@usdoj.gov 
Oliver.J.McDonald@usdoj.gov 
 
Counsel for Defendants 
Case 3:22-cv-00184   Document 25   Filed on 08/26/22 in TXSD   Page 2 of 41

 
 
i 
 
TABLE OF CONTENTS 
 
INTRODUCTION ................................................................................................................... 1 
BACKGROUND ..................................................................................................................... 2 
I. 
Factual Background ......................................................................................... 2 
A. 
FDA’s Critical Role in Protecting the Public Health .................................. 2 
B. 
The Approved Uses of Ivermectin and FDA’s Statements Regarding  
the Use of Ivermectin to Prevent or Treat COVID-19 ................................. 5 
II. 
Procedural History ........................................................................................... 9 
ARGUMENT ....................................................................................................................... 11 
I. 
This Case Should Be Dismissed for Lack of Subject Matter  
Jurisdiction ...................................................................................................... 11 
A. 
Plaintiffs Have Not Met Their Burden to Show Standing ....................... 11 
1. Plaintiffs’ Allegations of Injury Are Insufficient to the Extent They Do 
Not Allege Concrete Injuries to Plaintiffs .................................................. 12 
2. Plaintiffs’ Injuries Are Not Fairly Traceable to the Cited FDA 
Statements ....................................................................................................... 15 
3. Plaintiffs’ Injuries Are Not Likely Redressable by the Requested  
Relief ................................................................................................................ 18 
B. 
Plaintiffs Have Not Shown a Waiver of Sovereign Immunity ................ 21 
II. 
The Amended Complaint Fails to State a Plausible Claim for Relief .... 28 
CONCLUSION .................................................................................................................... 30 
 
 
Case 3:22-cv-00184   Document 25   Filed on 08/26/22 in TXSD   Page 3 of 41

 
 
ii 
 
TABLE OF AUTHORITIES 
Cases 
Adamski v. McHugh,  
 304 F. Supp. 3d 277 (D.D.C. 2015) ............................................................................. 28 
AIDS Healthcare Found., Inc. v. City of Baton Rouge/Par. of E. Baton Rouge,  
 No. 17-cv-229, 2017 WL 2899689 (M.D. La. July 7, 2017) ...................................... 14 
Alabama-Coushatta Tribe of Tex. v. United States,  
 757 F.3d 484 (5th Cir. 2014) ...................................................................... 11, 21, 24, 28 
Am. Paper Inst., Inc. v. EPA,  
 882 F.2d 287 (7th Cir. 1989) ........................................................................................ 25 
Amoco Prod. Co. v. Watson,  
 410 F.3d 722 (D.C. Cir. 2005) ...................................................................................... 24 
Ashcroft v. Iqbal,  
 556 U.S. 662 (2009) ....................................................................................................... 28 
Ass’n of Am. Physicians & Surgeons v. FDA, 
 13 F.4th 531 (6th Cir. 2021) ......................................................................................... 13 
Barry v. SEC,  
 No. 10-cv-4071, 2012 WL 760456 (E.D.N.Y. Mar. 7, 2012) ..................................... 25 
Bennett v. Spear, 
 520 U.S. 154 (1997) ..................................................................................... 16, 24, 25, 27  
BP Am. Prod. Co. v. Burton, 
 549 U.S. 84 (2006) ......................................................................................................... 24 
Brownback v. King, 
 141 S. Ct. 740 (2021) .................................................................................................... 11 
California v. Texas, 
 141 S. Ct. 2104 (2021) .................................................................................................. 13 
Camp v. Pitts, 
 411 U.S. 138 (1973) ....................................................................................................... 29 
Carr v. Saul, 
 141 S. Ct. 1352 (2021) .................................................................................................. 28 
Clapper v. Amnesty Int’l USA, 
 568 U.S. 398 (2013) ................................................................................................. 12, 17 
Cody Labs., Inc. v. Sebelius, 
 446 F. App’x 964 (10th Cir. 2011) .............................................................................. 25 
Case 3:22-cv-00184   Document 25   Filed on 08/26/22 in TXSD   Page 4 of 41

 
 
iii 
 
DaimlerChrysler Corp. v. Cuno,  
 547 U.S. 332 (2006) ....................................................................................................... 11 
Dalton v. Specter, 
 511 U.S. 462 (1994) ....................................................................................................... 26 
Daves v. Dallas Cnty., 
 22 F.4th 522 (5th Cir. 2022) ............................................................................. 11, 16, 17 
Dow Chem. v. EPA, 
 832 F.2d 319 (5th Cir. 1987) ........................................................................................ 25 
El Paso Cnty. v. Biden, 
 141 S. Ct. 2885 (2021), reh’g denied, 
 142 S. Ct. 51 (2021)....................................................................................................... 18 
El Paso Cnty. v. Trump, 
 982 F.3d 332 (5th Cir. 2020) .................................................................................. 18, 19 
Fleming v. U.S. Dep’t of Agric., 
 987 F.3d 1093 (D.C. Cir. 2021).................................................................................... 29 
Flue-Cured Tobacco Coop. Stabilization Corp. v. EPA, 
 313 F.3d 852 (4th Cir. 2002) ........................................................................................ 26 
Franklin v. Massachusetts, 
 505 U.S. 788 (1992) ....................................................................................................... 26 
Holistic Candlers & Consumers Ass’n v. FDA, 
 664 F.3d 940 (D.C. Cir. 2012) ...................................................................................... 25 
Indep. Equip. Dealers Ass’n v. EPA, 
 372 F.3d 420 (D.C. Cir. 2004) ...................................................................................... 25 
Indus. Safety Equip. Ass’n v. EPA, 
 837 F.2d 1115 (D.C. Cir. 1988).................................................................................... 24 
Int’l Tel. & Tel. Corp. v. Loc. 134, Int’l Bhd. of Elec. Workers, 
 419 U.S. 428 (1975) ....................................................................................................... 24 
Invention Submission Corp. v. Rogan, 
 357 F.3d 452 (4th Cir. 2004) .................................................................................. 26, 27 
Kowalski v. Tesmer, 
 543 U.S. 125 (2004) ........................................................................................... 13, 14, 15 
La. State v. U.S. Army Corps of Eng’rs, 
 834 F.3d 574 (5th Cir. 2016) ........................................................................................ 25 
 
Case 3:22-cv-00184   Document 25   Filed on 08/26/22 in TXSD   Page 5 of 41

 
 
iv 
 
Lane v. Pena, 
 518 U.S. 187 (1996) ....................................................................................................... 21 
Louisiana v. United States, 
 948 F.3d 317 (5th Cir. 2020) ........................................................................................ 21 
McCarthy v. Madigan, 
 503 U.S. 140 (1992) ....................................................................................................... 29 
McKart v. United States, 
 395 U.S. 185 (1969) ....................................................................................................... 29 
Mora v. Univ. of Tex. Sw. Med. Ctr., 
 469 F. App’x 295 (5th Cir. 2012) ................................................................................ 12 
Palm Valley Health Care, Inc. v. Azar, 
 947 F.3d 321 (5th Cir. 2020) ............................................................................ 28, 29, 30 
Physicians for Integrity in Med. Rsch., Inc. v. Ostroff, 
 670 F. App’x 450 (9th Cir. 2016) ................................................................................ 16 
Powers v. Ohio, 
 499 U.S. 400 (1991) ....................................................................................................... 14 
Qureshi v. Holder, 
 663 F.3d 778 (5th Cir. 2011) ............................................................................ 22, 25, 27 
Renal Physicians Ass’n v. U.S. Dep’t of Health & Hum. Servs.,  
 489 F.3d 1267 (D.C. Cir. 2007).............................................................................. 18, 21 
Shurtleff v. City of Bos., 
 142 S. Ct. 1583 (2022) .................................................................................................... 3 
Sierra Club v. Peterson, 
 228 F.3d 559 (5th Cir. 2000) ........................................................................................ 22 
Simic v. City of Chi., 
 851 F.3d 734 (7th Cir. 2017) ........................................................................................ 13 
Simon v. E. Ky. Welfare Rts. Org., 
 426 U.S. 26 (1976) ......................................................................................................... 19 
Sims v. Apfel, 
 530 U.S. 103 (2000) ....................................................................................................... 29 
Spokeo, Inc. v. Robins, 
 578 U.S. 330 (2016) ........................................................................................... 12, 15, 18 
Sprint Nextel Corp. v. FCC, 
 508 F.3d 1129 (D.C. Cir. 2007).................................................................................... 22 
Case 3:22-cv-00184   Document 25   Filed on 08/26/22 in TXSD   Page 6 of 41

 
 
v 
 
Steel Co. v. Citizens for a Better Env’t, 
 523 U.S. 83 (1998) ......................................................................................................... 11 
Summers v. Earth Island Inst., 
 555 U.S. 488 (2009) ....................................................................................................... 15 
Swisher Int’l, Inc. v. FDA, 
 No. 21-13088, 2022 WL 320889 (11th Cir. Feb. 3, 2022) .......................................... 25 
Sykes v. FEC, 
 335 F. Supp. 2d 84 (D.D.C. 2004) ............................................................................... 20 
TransUnion LLC v. Ramirez, 
 141 S. Ct. 2190 (2021) .................................................................................................. 12 
United States v. L.A. Tucker Truck Lines, Inc., 
 344 U.S. 33 (1952) ......................................................................................................... 28 
Walmart Inc. v. U.S. Dep’t of Just., 
 21 F.4th 300 (5th Cir. 2021) ......................................................................................... 21 
Statutes 
5 U.S.C. §  
 551(4) ............................................................................................................................. 24 
 551(6) ............................................................................................................................. 24 
 551(7) ............................................................................................................................. 24 
 551(10) ........................................................................................................................... 24 
 551(13) ..................................................................................................................... 22, 23 
 702 ................................................................................................................................. 21 
 704 ................................................................................................................................. 21 
21 U.S.C. §  
 301 ................................................................................................................................... 2 
 321(p) .............................................................................................................................. 2 
 331(d) .............................................................................................................................. 2 
 355(a) ............................................................................................................................... 2 
 355(b) ............................................................................................................................... 2 
 355-1 ................................................................................................................................ 3 
 360(b) ............................................................................................................................... 3 
Case 3:22-cv-00184   Document 25   Filed on 08/26/22 in TXSD   Page 7 of 41

 
 
vi 
 
 360b(a)(1)(B) ................................................................................................................... 3 
 360b(a)(1)(C) .................................................................................................................. 3 
 360b(a)(1)(D) .................................................................................................................. 3 
 360bbb-3 ......................................................................................................................... 3 
 360ccc .............................................................................................................................. 3 
 360ccc-1 ........................................................................................................................... 3 
 375(b) ............................................................................................................................... 3 
 393(b)(1) .......................................................................................................................... 3 
 393(b)(2)(B) ..................................................................................................................... 3 
Regulations 
21 C.F.R. §  
 10.25(a) .......................................................................................................................... 30 
 10.30 .............................................................................................................................. 30 
 10.45 .............................................................................................................................. 30 
Other Authorities 
15 Moore’s Federal Practice - Civil § 101.42 (2022) .................................................... 20 
  
Case 3:22-cv-00184   Document 25   Filed on 08/26/22 in TXSD   Page 8 of 41

 
 
1 
 
INTRODUCTION 
During the COVID-19 pandemic, the U.S. Food and Drug Administration 
(“FDA”) received multiple reports of patients who required medical attention, 
including hospitalization, after self-medicating with ivermectin products 
intended for livestock. In response, FDA posted an article on its website 
explaining that drug products containing ivermectin have been approved for 
certain uses in humans and that other drug products containing ivermectin have 
been approved for certain uses in animals, but that they have not been approved 
or authorized to prevent or treat COVID-19. The article warned consumers that it 
could be dangerous for humans to use animal versions of ivermectin or, in 
certain circumstances, even human versions, to treat COVID-19. FDA tweeted 
links to the article and communicated similar information through an Instagram 
post, two FAQ pages on its website, and a letter to two organizations. 
Plaintiffs are three doctors who prescribed ivermectin or promoted its use to 
prevent or treat COVID-19. They allege that their ability to practice medicine was 
harmed and that FDA’s statements regarding the use of ivermectin to prevent or 
treat COVID-19 indirectly caused that harm by influencing third parties, such as 
their employers. Plaintiffs’ claims, however, suffer from several fatal defects. 
First, the Amended Complaint should be dismissed for lack of subject matter 
jurisdiction under Rule 12(b)(1) because Plaintiffs fail to meet their burden to 
show standing. Plaintiffs’ allegations of injury are insufficient to the extent they 
do not allege personal, concrete injuries to Plaintiffs. Their alleged injuries also 
are not traceable to the FDA statements cited in the Amended Complaint, which 
were purely informational, but instead were caused by the decisions of 
independent third parties, such as their employers. Finally, their alleged injuries 
Case 3:22-cv-00184   Document 25   Filed on 08/26/22 in TXSD   Page 9 of 41

 
 
2 
 
are not likely to be redressed by the requested relief because even if the Court 
vacated the cited statements, that would not likely cause those independent third 
parties to change their decisions. 
Second, the Amended Complaint should be dismissed under Rule 12(b)(1) 
for the additional reason that Plaintiffs fail to identify an applicable waiver of 
sovereign immunity. The Administrative Procedure Act (“APA”) does not 
provide a waiver because Plaintiffs have not shown that the cited FDA 
statements are “agency action” or “final agency action.” The cited statements are 
not “agency action” because they do not meet the APA’s definition of that term. 
They also are not “final.” They did not determine rights or obligations or have 
any legal consequences, but instead were purely informational. 
Finally, the Amended Complaint should be dismissed under Rule 12(b)(6) 
for failure to state a claim. Plaintiffs do not allege that the arguments they raise in 
this lawsuit were ever before FDA for administrative resolution. Thus, Plaintiffs 
are foreclosed from raising those arguments before this Court. 
BACKGROUND 
I. Factual Background 
A. FDA’s Critical Role in Protecting the Public Health 
The Federal Food, Drug, and Cosmetic Act (“FDCA”) regulates the 
manufacturing, labeling, and distribution of drugs in the United States. 21 U.S.C. 
§ 301 et seq. Under the FDCA’s comprehensive regulatory scheme, it is unlawful 
to distribute a “new drug” in interstate commerce without FDA approval, which 
requires the manufacturer to show that the drug is both safe and effective for its 
intended uses. Id. §§ 321(p), 331(d), 355(a), (b). The FDCA makes it similarly 
Case 3:22-cv-00184   Document 25   Filed on 08/26/22 in TXSD   Page 10 of 41

 
 
3 
 
unlawful to distribute a “new animal drug,” unless FDA approves it as safe and 
effective for a particular intended use. Id. § 360(b).1  
Where FDA has approved a drug for a particular human use, the agency 
generally does not object if physicians choose to prescribe that drug for some 
other unapproved use (sometimes called an “off-label” use) for their patients.2 
This general position on the off-label prescription of human drugs does not, 
however, extend to prescribing animal drugs for human use. FDA does not 
evaluate the safety of animal drugs for use in humans, and the use of animal 
drugs in humans can cause serious harm. 
Congress charged FDA with protecting the public health and ensuring the 
safety and effectiveness of medical products. See 21 U.S.C. § 393(b)(1), (b)(2)(B). 
In that capacity, the agency routinely communicates with the public, including 
health care providers and consumers, regarding medical products’ safety and 
efficacy. See, e.g., id. § 375(b) (FDA may “disseminate[] information” about the 
products it regulates “in situations involving . . . imminent danger to health or 
gross deception of the consumer”); cf. Shurtleff v. City of Bos., 142 S. Ct. 1583, 1589 
(2022) (“When the government wishes to state an opinion, to speak for the 
community, to formulate policies, or to implement programs, it naturally chooses 
what to say and what not to say. That must be true for government to work.” 
(internal citation omitted)). In addition to reviewing proposed labeling for 
 
1 A new animal drug may also be legally distributed for use in animals under 
limited other circumstances. See 21 U.S.C. §§ 360b(a)(1)(B)–(D), 360bbb-3, 360ccc, 
360ccc-1. 
2 In certain circumstances, FDA imposes restrictions on prescribing approved 
drugs. See, e.g., 21 U.S.C. § 355-1 (authorizing FDA to require formal plans for 
certain drugs to help ensure that those drugs’ benefits outweigh their risks). 
Case 3:22-cv-00184   Document 25   Filed on 08/26/22 in TXSD   Page 11 of 41

 
 
4 
 
medical products, FDA communicates directly to the public about the safety and 
effectiveness of medical products through, among other things, the Federal 
Register, its website, social media, direct mailings, and journals. These 
communications include Drug Safety Communications, press releases, articles in 
FDA Consumer Magazine, notices of recalls, articles in scientific journals, 
YouTube videos, Instagram posts, and tweets regarding safety information about 
human medical products on @FDAMedWatch. 
To take a few examples: In October 2002, FDA warned the public about a 
bone cement used in vertebroplasty and kyphoplasty procedures even though 
the product had long been used in other procedures.3 In September 2017, FDA 
issued a drug safety communication that warned about incorrect dosing of the 
liver disease medicine Ocaliva.4 In September 2020, FDA issued a warning 
regarding a “Benadryl Challenge” encouraged in videos on the social media 
application TikTok after receiving reports of teenagers requiring emergency 
treatment or dying after participating in such challenges.5 And in March 2021, 
FDA issued a warning that, although the over-the-counter nasal decongestant 
propylhexedrine is safe and effective when used as directed, the abuse and 
misuse of propylhexedrine could lead to serious harm, such as heart and mental 
health problems, hospitalization, disability, or death.6 
 
3 See http://web.archive.org/web/20021201185006/http://www.fda.gov/
cdrh/safety/bonecement.html. 
4 See https://go.usa.gov/xSMKp. 
5 See https://go.usa.gov/xSMKw. 
6 See https://go.usa.gov/xSMKG. 
Case 3:22-cv-00184   Document 25   Filed on 08/26/22 in TXSD   Page 12 of 41

 
 
5 
 
B. The Approved Uses of Ivermectin and FDA’s Statements Regarding 
the Use of Ivermectin to Prevent or Treat COVID-19 
Drug products containing ivermectin as the active ingredient are approved 
to treat parasites and certain skin conditions in humans.7 FDA has also approved 
drug products containing ivermectin to treat certain parasites in various animal 
species and to prevent heartworm disease in some small animal species, with 
dosages and formulations that vary based on the species and the condition to be 
treated. See, e.g., Ex. 2 at 2.8 For example, the labeling for the product marketed 
under the name Zimecterin Gold, Am. Compl. ¶ 75, which is approved for use in 
horses and available without a prescription (i.e., over-the-counter), warns that 
the product is “[n]ot for use in humans” and “should not be used in other animal 
species” because “severe adverse reactions,” including death, could result.9 The 
FDA-approved labeling for human-use Stromectol® (ivermectin) describes 
adverse events observed in cases of accidental intoxication with or significant 
exposure to animal-use versions of ivermectin, including rash, nausea, vomiting, 
diarrhea, seizure, difficulty breathing, abdominal pain, and contact dermatitis.10 
During the COVID-19 pandemic, FDA received multiple reports of patients 
who required medical attention, including hospitalization, after self-medicating 
with ivermectin products intended for livestock. Ex. 1 at 3; Ex. 19 at 2. In 
response, FDA made public statements regarding the use of ivermectin to 
prevent or treat COVID-19. The Amended Complaint identifies seven such 
 
7 See https://go.usa.gov/xSMkc (label for Stromectol, the drug product 
referenced in ECF No. 12 (Am. Compl.) ¶ 74). 
8 Citations to exhibits refer to the exhibits to the Amended Complaint. Cited 
page numbers refer to the page numbers assigned by PACER. 
9 See https://go.usa.gov/xSM8F. 
10 See https://go.usa.gov/xSMkc (Stromectol label), at 8–9. 
Case 3:22-cv-00184   Document 25   Filed on 08/26/22 in TXSD   Page 13 of 41

 
 
6 
 
statements: an article and two FAQs posted on FDA’s website, Exs. 1–3, 19, two 
tweets linking to the article, Exs. 4, 7, an Instagram post, Ex. 6, and a letter to two 
organizations, Ex. 22 (hereafter, the “cited statements” or “cited FDA 
statements”). None of the cited statements asked or instructed doctors not to 
prescribe ivermectin products to prevent or treat COVID-19.  
The article, titled “Why You Should Not Use Ivermectin to Treat or Prevent 
COVID-19,” was first posted on March 5, 2021. Ex. 19. It was directed to 
consumers. See, e.g., id. at 3 (“Never use medications intended for animals on 
yourself.”). It noted the “growing interest” in using ivermectin to treat COVID-19 
and explained that “some initial research” on this use was “underway,” but that 
FDA “ha[d] not reviewed data to support [this] use of ivermectin” and “ha[d] 
not approved ivermectin” for this use. Id. at 2. It warned that using a COVID-19 
treatment that is “not approved or authorized by the FDA, unless part of a 
clinical trial, can cause serious harm.” Id. It explained that ivermectin could be 
dangerous if, for example, it “interact[s] with other medications,” and it advised 
that “[i]f you have a prescription for ivermectin for an FDA-approved use, get it 
from a legitimate source and take it exactly as prescribed.” Id. at 3. 
The article also described the conditions for which drug products containing 
ivermectin are approved for use in humans and the conditions for which drug 
products containing ivermectin are approved for use in animals, and it explained 
that the human versions are “very different” from the animal versions. Id. at 3. In 
particular, it explained that “[m]any inactive ingredients found in animal 
products aren’t evaluated for use in people” or are “included in much greater 
quantity than those used in people.” Id. It discussed the risks of humans taking 
Case 3:22-cv-00184   Document 25   Filed on 08/26/22 in TXSD   Page 14 of 41

 
 
7 
 
ivermectin products approved for use in animals and advised: “Never use 
medications intended for animals on yourself.” Id. 
The current version of the article, which has the same title and has been 
online since September 7, 2021, contained much of the same content. See Ex. 1. 
However, the current version removed the statement that FDA had not yet 
“reviewed data to support [the] use of ivermectin” to prevent or treat COVID-19 
and instead emphasized that FDA has not approved ivermectin to prevent or 
treat COVID-19 or granted emergency use authorization for that use. Id. at 2. The 
article advised, “If your health care provider writes you an ivermectin 
prescription, fill it through a legitimate source such as a pharmacy, and take it 
exactly as prescribed.” Id. at 3 (emphasis in original). And the article 
recommended: “Talk to your health care provider about available COVID-19 
vaccines and treatment options. Your provider can help determine the best option for 
you, based on your health history.” Id. at 4 (emphasis added). 
FDA publicized its article on Twitter with tweets linking to the article. For 
example, an August 21, 2021 tweet stated, “You are not a horse. You are not a 
cow. Seriously, y’all. Stop it,” Ex. 4 at 2, and an April 26, 2022 tweet stated, “Hold 
your horses, y’all. Ivermectin may be trending, but it still isn’t authorized or 
approved to treat COVID-19,” Ex. 7 at 2. Both tweets included images of a horse. 
Ex. 4 at 2; Ex. 7 at 2. Similarly, on August 21, 2021, FDA posted on Instagram an 
image of a horse with the caption: “You are not a horse. Stop it with the 
#Ivermectin. It’s not authorized for treating #COVID.” Ex. 6 at 2. 
On April 10, 2020, FDA posted on its website a frequently-asked-questions 
webpage titled “FAQ: COVID-19 and Ivermectin Intended for Animals.” Ex. 2. 
Case 3:22-cv-00184   Document 25   Filed on 08/26/22 in TXSD   Page 15 of 41

 
 
8 
 
The FAQ was directed to consumers. See, e.g., id. at 2 (answering the question, 
“Should I take ivermectin to prevent or treat COVID-19?”). The FAQ explained 
that “there are approved uses for ivermectin in people and animals, but it is not 
approved for the prevention or treatment of COVID-19.” Id. It advised that 
“[a]ny use of ivermectin for the prevention or treatment of COVID-19 should be 
avoided as its benefits and safety for these purposes have not been established. 
Data from clinical trials are necessary for us to determine whether ivermectin is 
safe and effective in treating or preventing COVID-19.” Id. The FAQ noted that 
although “[a] recently released research article described the effect of ivermectin 
on SARS-CoV-2 in a laboratory setting . . . [a]dditional testing [was] needed to 
determine whether ivermectin might be appropriate to prevent or treat [COVID-
19].” Id. (citations omitted). Nonetheless, the FAQ recognized that doctors may 
choose to prescribe ivermectin products approved for human use to prevent or 
treat COVID-19, and it advised consumers “not [to] take any medicine to treat or 
prevent COVID-19 unless it has been prescribed to you by your health care provider 
and acquired from a legitimate source.” Id. (emphasis added). Finally, the FAQ 
explained that “[p]eople should never take animal drugs” because that “could 
cause serious harm.” Id. A similar FAQ webpage also advised against taking 
ivermectin “for the prevention or treatment of COVID-19,” explaining that it was 
not “approved or authorized” for those uses, and included a link to the cited 
FDA article on that topic. Ex. 3 at 2. Like the cited article and the other cited FAQ, 
this FAQ was also directed to consumers. See id. (answering the question, 
“Should I take ivermectin to prevent or treat COVID-19?”). 
Case 3:22-cv-00184   Document 25   Filed on 08/26/22 in TXSD   Page 16 of 41

 
 
9 
 
In December 2021, FDA sent a letter to the Federation of State Medical 
Boards and the National Association of Boards of Pharmacy. The letter was not 
directed to physicians’ prescribing practices, but instead focused on FDA’s 
receipt of “complaints about compounding pharmacies selling drug products 
containing ivermectin, claiming that they can treat or prevent COVID-19.” Ex. 22 at 
2 (emphasis added). The letter explained that although “ongoing” clinical trials 
were investigating ivermectin’s potential use to prevent or treat COVID-19, the 
“currently available data [did] not show” that the drug is “safe or effective” for 
that use. Id. The letter concluded that using ivermectin to prevent or treat 
COVID-19 “may pose risks to patient health” and that products claiming to be 
safe and effective for that purpose when they have not been shown to be “can 
place consumers at risk of serious harm.” Id.11 
II. Procedural History 
Plaintiffs—three physicians who prescribed ivermectin or promoted its use 
to prevent or treat COVID-19—filed suit on June 2, 2022. ECF No. 1; Am. Compl. 
¶¶ 10–43. They filed an Amended Complaint on August 8, 2022. They allege that 
Bowden’s and Marik’s employers forced them to resign from their jobs; Bowden 
 
11 The cited FDA statements were consistent with an April 2020 letter from 
FDA to “Stakeholders,” which Plaintiffs apparently do not challenge. In that 
letter, FDA explained that “[a]dditional testing is needed to determine whether 
ivermectin might be safe or effective to prevent or treat . . . COVID-19.” Ex. 27 at 
23–24. The letter expressed FDA’s “concern[] about the health of consumers who 
may self-medicate by taking ivermectin products intended for animals, thinking 
they can be a substitute for ivermectin intended for humans.” Id. It warned 
against the human use of animal drugs because they “can cause serious harm in 
people,” as “FDA has only evaluated their safety and effectiveness in the 
particular animal species for which they are labeled.” Id. The letter advised that 
“[p]eople should not take any form of ivermectin unless it has been prescribed to 
them by a licensed health care provider and is obtained through a legitimate source.” Id. 
(emphasis added). 
Case 3:22-cv-00184   Document 25   Filed on 08/26/22 in TXSD   Page 17 of 41

 
 
10 
 
was “derided by” her employer and “publicly ridiculed”; patients have delayed 
seeking Bowden’s care; and Apter faces professional disciplinary proceedings. 
E.g., id. ¶¶ 18, 21, 29, 42; 121. They further allege that the cited FDA statements 
interfered with their ability to practice medicine and exercise professional 
medical judgment, and stopped them from using ivermectin to treat COVID-19. 
E.g., id. ¶¶ 4, 10, 14, 24–25, 42, 106, 118, 121–22, 148. They also allege that Apter’s 
and Bowden’s patients were harmed because pharmacists refused to fill some 
patients’ ivermectin prescriptions; insurance companies refused to pay for those 
prescriptions; and some patients declined or delayed treatment with ivermectin. 
E.g., id. ¶¶ 15–17, 24, 27–29. They claim that these alleged injuries were indirectly 
caused by the cited FDA statements. Id. ¶¶ 10–43. 
Count One seeks “non-statutory review” on the theory that the cited FDA 
statements exceeded FDA’s statutory authority.12 Id. ¶¶ 129–31. Count Two 
alleges that the cited statements were “arbitrary and capricious” under the APA 
because they were not the product of reasoned decision-making. Id. ¶¶ 132–44. 
Counts Three and Four are also asserted under the APA and, like Count One, 
claim that the cited statements exceeded FDA’s statutory authority. Id. ¶¶ 145–
56. Count Five seeks a declaratory judgment for the reasons stated in the other 
counts. Id. ¶¶ 157–59. 
 
12 Plaintiffs appear to concede FDA’s authority to warn consumers not to use 
animal-use ivermectin. See, e.g., Am. Compl. ¶ 1 (“The FDA generally cannot ban 
particular uses of human drugs once they are otherwise approved . . . .” 
(emphasis added)). Plaintiffs also concede FDA’s authority “to communicate the 
risks of using approved drugs.” Id. ¶ 151. 
Case 3:22-cv-00184   Document 25   Filed on 08/26/22 in TXSD   Page 18 of 41

 
 
11 
 
ARGUMENT 
The Amended Complaint should be dismissed for two independent reasons. 
First, it should be dismissed for lack of subject matter jurisdiction under Rule 
12(b)(1) because Plaintiffs have failed to show that they have standing and have 
failed to identify an applicable waiver of sovereign immunity. Second, the 
Amended Complaint should be dismissed for failure to state a claim under Rule 
12(b)(6) because Plaintiffs do not plausibly allege that the arguments they raise 
were ever before FDA for administrative resolution.  
I. This Case Should Be Dismissed for Lack of Subject Matter Jurisdiction 
Subject matter jurisdiction must “be established as a threshold matter.” Steel 
Co. v. Citizens for a Better Env’t, 523 U.S. 83, 94–95 (1998). The Court is 
“presume[d]” to “lack jurisdiction” unless Plaintiffs meet their “burden of 
establishing it.” DaimlerChrysler Corp. v. Cuno, 547 U.S. 332, 342 n.3 (2006) 
(quotations omitted); see Brownback v. King, 141 S. Ct. 740, 749 (2021) (plaintiff 
“must plausibly allege all jurisdictional elements”). Challenges to subject matter 
jurisdiction must be resolved “prior to addressing the merits.” Alabama-Coushatta 
Tribe of Tex. v. United States, 757 F.3d 484, 487 (5th Cir. 2014); see Daves v. Dallas 
Cnty., 22 F.4th 522, 532 (5th Cir. 2022) (en banc). For the reasons discussed below, 
Plaintiffs have failed to meet their burden to show subject matter jurisdiction. See 
DaimlerChrysler, 547 U.S. at 342 n.3. 
A. Plaintiffs Have Not Met Their Burden to Show Standing 
To show Article III standing, Plaintiffs “must clearly allege . . . facts 
demonstrating” (1) an injury in fact that is “concrete, particularized, and actual 
or imminent”; (2) “fairly traceable to the challenged conduct of the defendant”; 
and (3) likely “redressable by a favorable ruling.” Spokeo, Inc. v. Robins, 578 U.S. 
Case 3:22-cv-00184   Document 25   Filed on 08/26/22 in TXSD   Page 19 of 41

 
 
12 
 
330, 338 (2016); Clapper v. Amnesty Int’l USA, 568 U.S. 398, 409 (2013). Plaintiffs 
“must demonstrate standing for each claim . . . and for each form of relief.” 
TransUnion LLC v. Ramirez, 141 S. Ct. 2190, 2208 (2021). 
1. Plaintiffs’ Allegations of Injury Are Insufficient to the Extent 
They Do Not Allege Concrete Injuries to Plaintiffs 
Many of Plaintiffs’ allegations fail to show the requisite injury in fact because 
they do not allege concrete injuries to Plaintiffs. For example, Plaintiffs allege 
that FDA “interfere[d] with the practice of medicine.” Am. Compl. ¶ 10; see also, 
e.g., id. ¶¶ 5, 7, 24, 42, 121, 148. But that vague and conclusory statement does not 
adequately allege a concrete injury to Plaintiffs. See Spokeo, 578 U.S. at 338; 
Clapper, 568 U.S. at 409. Plaintiffs also allege that the cited FDA statements 
“stopp[ed] doctors from using ivermectin to treat COVID-19,” Am. Compl. 
¶ 106; see also id. ¶¶ 4, 25, 118, 121, 148, “interfered with [their] ability to exercise 
professional medical judgment in practicing medicine, id. ¶ 14, or put “pressure 
on [their] professional judgment,” id. ¶¶ 121–22. Yet Plaintiffs allege that they 
have continued to prescribe ivermectin to prevent or treat COVID-19 despite the 
cited FDA statements. See id. ¶¶ 22, 26 (Bowden “continues to treat COVID-19 
patients” and “prescribes ivermectin to treat COVID-19”); see also id. ¶ 29 
(Bowden’s patient filled ivermectin prescription); id. ¶ 13 (Apter “has frequently 
prescribed ivermectin” to patients). Thus, Plaintiffs have not plausibly alleged 
that the cited FDA statements injured them. See Mora v. Univ. of Tex. Sw. Med. 
Ctr., 469 F. App’x 295, 299 (5th Cir. 2012) (an “allegation [that] is contradicted by 
the other facts alleged in the complaint” is “implausible on its face”).  
In addition, Apter alleges that he “has been referred to the Washington 
Medical Commission and Arizona Medical Board for disciplinary proceedings 
Case 3:22-cv-00184   Document 25   Filed on 08/26/22 in TXSD   Page 20 of 41

 
 
13 
 
for prescribing ivermectin to treat COVID-19.” Am. Compl. ¶ 18; see also id. 
¶ 121. But he does not allege that these disciplinary proceedings have resulted in 
any adverse action against him, that they have deprived him of due process, or 
that they have caused him any other concrete injury. Merely “[h]aving to defend 
oneself in a legal proceeding ordinarily does not give rise to a redressable 
injury.” Simic v. City of Chi., 851 F.3d 734, 739–40 (7th Cir. 2017) (explaining that, 
although “being prosecuted and tried without probable cause [might] give[] rise 
to a federal constitutional claim,” simply “undergoing trial in a criminal 
prosecution does not give rise to a due process violation”). 
Plaintiffs also make allegations about alleged harm to independent third 
parties. For example, Plaintiffs allege injury to their patients, such as pharmacists 
refusing to fill their patients’ ivermectin prescriptions, insurance companies 
refusing to pay for those prescriptions, and patients declining or delaying 
treatment with ivermectin. E.g., Am. Compl. ¶¶ 15–17, 24, 27–29. Plaintiffs also 
make allegations about injuries to unnamed doctors and patients. E.g., id. ¶¶ 4–5, 
7, 10, 16–17, 25, 43, 105–06, 109, 114, 118, 148. But these alleged injuries to 
independent third parties do not show any “personal injury” to Plaintiffs. 
California v. Texas, 141 S. Ct. 2104, 2113 (2021) (quotations omitted); see Kowalski v. 
Tesmer, 543 U.S. 125, 129 (2004) (“We have adhered to the rule that a party 
generally must assert his own legal rights and interests, and cannot rest his claim 
to relief on the legal rights or interests of third parties.” (quotations omitted)); 
Ass’n of Am. Physicians & Surgeons v. FDA, 13 F.4th 531, 544 (6th Cir. 2021) 
(observing in dicta that plaintiff “has not identified a harm to physicians merely 
because the drug may not be available to patients”). 
Case 3:22-cv-00184   Document 25   Filed on 08/26/22 in TXSD   Page 21 of 41

 
 
14 
 
The Supreme Court has identified “certain, limited exceptions” to “[t]his 
fundamental restriction on [courts’] authority” when “three important criteria 
are satisfied”: (1) “The litigant must have suffered an injury in fact”; (2) “the 
litigant must have a close relation to the third party”; and (3) “there must exist 
some hindrance to the third party’s ability to protect his or her own interests.” 
Powers v. Ohio, 499 U.S. 400, 410–11 (1991) (citations and quotations omitted); see 
Kowalski, 543 U.S. at 128–30. Here, Plaintiffs fail to satisfy at least the third 
criterion because they have not alleged any “hindrance” to these third parties’ 
ability to protect their own interests. For example, Plaintiffs have not shown why 
patients whose pharmacists allegedly refused to fill their ivermectin 
prescriptions are unable or unwilling to seek legal or other relief themselves. See 
AIDS Healthcare Found., Inc. v. City of Baton Rouge/Par. of E. Baton Rouge, No. 17-
cv-229, 2017 WL 2899689, at *4 (M.D. La. July 7, 2017) (medical clinic “failed to 
demonstrate that it has standing to rely on alleged injuries sustained by its 
patients” because “there is no indication that [those patients] are unable or 
unwilling to bring claims on their own behalves”). Plaintiffs therefore cannot rely 
on alleged injuries to their patients; contrary to their allegation, there is no 
general rule allowing physicians to “invoke the rights of their actual or potential 
patients.” Am. Compl. ¶ 125. Similarly, Plaintiffs have not shown why unnamed 
doctors and patients who were allegedly harmed by the cited FDA statements 
are unable or unwilling to seek legal or other relief themselves. 
Finally, the Supreme Court has recognized that plaintiffs may have standing 
to assert the rights of third parties if “enforcement of the challenged restriction 
against the litigant would result indirectly in the violation of third parties’ rights.” 
Case 3:22-cv-00184   Document 25   Filed on 08/26/22 in TXSD   Page 22 of 41

 
 
15 
 
Kowalski, 543 U.S. at 130 (emphasis in original) (quotations omitted). But here, no 
FDA “restriction” is being “enforce[d]” against Plaintiffs. Plaintiffs challenge 
only informational statements by FDA that carried no legal consequences for 
Plaintiffs or anyone else. 
2. Plaintiffs’ Injuries Are Not Fairly Traceable to the Cited FDA 
Statements 
To the extent Plaintiffs have shown an adequate personal injury, they have 
not shown that such injury is “fairly traceable” to the cited FDA statements. 
Spokeo, 578 U.S. at 338. The cited statements simply communicated FDA’s 
recommendations regarding the use of ivermectin to prevent or treat COVID-19. 
They “neither require[d] nor forb[ade] any action on the part of” Plaintiffs or 
anyone else, Summers v. Earth Island Inst., 555 U.S. 488, 493–94 (2009), nor did 
they direct that Plaintiffs face any adverse consequences for prescribing or 
promoting ivermectin to prevent or treat COVID-19. 
Unable to allege that the cited FDA statements directly caused their alleged 
injuries, Plaintiffs rely instead on an indirect theory of causation. Regarding 
Bowden, however, the Amended Complaint does not allege that her employer’s 
decision to “deride[]” her and “force[] [her] to resign,” Am. Compl. ¶ 21, was 
based on the cited FDA statements, so Plaintiffs fail to show traceability for those 
alleged injuries. For other alleged injuries, Plaintiffs allege an indirect causal 
chain: the cited statements allegedly influenced the thinking of independent 
third parties about the use of ivermectin to prevent or treat COVID-19, and those 
independent third parties then allegedly took actions that caused Plaintiffs’ 
injuries. For example, Plaintiffs allege that the cited FDA statements influenced 
decisions by unnamed third parties to refer them to state medical boards for 
Case 3:22-cv-00184   Document 25   Filed on 08/26/22 in TXSD   Page 23 of 41

 
 
16 
 
disciplinary proceedings, by their employers to force them to resign, by their 
patients to delay seeking their care, and by members of the public to berate them. 
E.g., Am. Compl. ¶¶ 18, 29, 41–42, 105. But standing “is ordinarily substantially 
more difficult to establish” when “a causal relation between injury and 
challenged action depends upon the decision of an independent third 
party.” Daves, 22 F.4th at 542–44 (quotations omitted). And the third-party 
actions that allegedly injured Plaintiffs were independent—they did not result 
from any “determinative or coercive effect” of the cited FDA statements. Bennett 
v. Spear, 520 U.S. 154, 169 (1997); see also Physicians for Integrity in Med. Rsch., Inc. 
v. Ostroff, 670 F. App’x 450, 451 (9th Cir. 2016) (“Patients who choose to stop 
seeing Dr. Desai as a result of Dr. Desai’s comments regarding roflumilast, or 
who end up finding him less reputable, are making an independent choice 
unrelated to the FDA’s actions.”). 
Plaintiffs cannot establish standing based on this indirect causal chain 
because they have not shown that the third-party decisions that allegedly 
harmed them were a “predictable” response to the cited FDA statements. Daves, 
22 F.4th at 543 (quotations omitted). The cited statements did not state that 
doctors may not (or even should not) prescribe human-use ivermectin to prevent 
or treat COVID-19. Instead, they generally recommended to consumers (who can 
purchase the ivermectin product for horses over-the-counter) that they should 
not take ivermectin to prevent or treat COVID-19.13 Moreover, the September 
 
13 Similarly, FDA’s December 2021 letter to the Federation of State Medical 
Boards and the National Association of Boards of Pharmacy—which was issued 
after Bowden’s resignation—does not state that doctors should not prescribe 
human-use ivermectin to prevent or treat COVID-19. See Ex. 22. Instead, it 
addressed “compounding pharmacies selling drug products containing 
ivermectin, claiming that they can treat or prevent COVID-19.” Id. at 2. 
Case 3:22-cv-00184   Document 25   Filed on 08/26/22 in TXSD   Page 24 of 41

 
 
17 
 
2021 article and the April 2020 FAQ advised consumers that “[i]f your health care 
provider writes you an ivermectin prescription, fill it through a legitimate source 
such as a pharmacy, and take it exactly as prescribed,” indicating that doctors 
have discretion to prescribe ivermectin products. Ex. 1 at 3; see also Ex. 2 at 2.14 
The article likewise recommended that patients talk to their doctors to determine 
their best treatment options. Ex. 1 at 2.  
Thus, assuming the third parties that allegedly injured Plaintiffs read the 
cited FDA statements, they would likely have concluded that FDA wanted 
consumers to be aware of the agency’s concerns about using ivermectin to 
prevent or treat COVID-19, but that doctors have discretion to prescribe 
ivermectin for that use. Plaintiffs allege, however, that these third parties 
referred them to state medical boards for disciplinary proceedings, forced them 
to resign, delayed seeking their care, and “derided” and “ridiculed” them for 
prescribing ivermectin to prevent or treat COVID-19. E.g., Am. Compl. ¶¶ 15, 
18, 21, 27–29, 42, 105. These actions were not a “predictable” response to the cited 
FDA statements, Daves, 22 F.4th at 543 (quotations omitted), and only through 
impermissible “speculation” could they be attributed to those statements, 
Clapper, 568 U.S. at 414.15 
 
14 The cited tweets included links to the article. See Ex. 4; Ex. 7; Am. Compl. 
¶¶ 92, 100. Although the March 2021 version of this article stated that patients 
should use ivermectin if it was prescribed “for an FDA-approved use,” Ex. 19 at 
3, that text was removed when the article was updated in September 2021, and 
Plaintiffs do not allege that any of the third-party conduct that allegedly injured 
them was caused by the earlier version of the article. See infra n.23. 
15 Even if Plaintiffs could assert alleged injuries to independent third parties, 
they would fail to show traceability. For example, Plaintiffs have not shown that 
pharmacies’ alleged refusal to fill patients’ ivermectin prescriptions or insurance 
companies’ alleged refusal to pay for those prescriptions were a “predictable” 
response to the cited FDA statements. Daves, 22 F.4th at 543 (quotations omitted).  
Case 3:22-cv-00184   Document 25   Filed on 08/26/22 in TXSD   Page 25 of 41

 
 
18 
 
3. Plaintiffs’ Injuries Are Not Likely Redressable by the Requested 
Relief 
Even if the Court granted Plaintiffs’ requested relief, that would not likely 
redress their injuries. Spokeo, 578 U.S. at 338; see El Paso Cnty. v. Trump, 982 F.3d 
332, 341 (5th Cir. 2020), cert. denied sub nom. El Paso Cnty. v. Biden, 141 S. Ct. 2885 
(2021), reh’g denied, 142 S. Ct. 51 (2021). Plaintiffs seek, inter alia, a declaration that 
FDA did not have authority to make the cited statements and an injunction 
prohibiting FDA from making such statements. Am. Compl. 43–44. They argue 
that, if the cited FDA statements are vacated, “[h]ealth professionals and state 
regulatory boards” will “revert to [the] norm” of “support[ing] the off-label 
prescription of approved drugs” and that “patients will no longer be caught 
between” the cited statements and “Plaintiffs’ advice.” Id. ¶ 124.16 
A ruling that the cited statements exceeded FDA’s legal authority or violated 
the APA would not likely redress Plaintiffs’ injuries because it would not likely 
change the independent third parties’ scientific understanding of the risks and 
benefits of using ivermectin to prevent or treat COVID-19. Thus, the requested 
relief would not likely give the third parties any reason to reconsider their 
actions that allegedly harmed Plaintiffs.17 See Renal Physicians Ass’n v. U.S. Dep’t 
of Health & Hum. Servs., 489 F.3d 1267, 1278 (D.C. Cir. 2007) (even if 
governmental action is a “contributing factor in bringing about a specific harm,” 
 
16 Plaintiffs also argue that their “professional judgment would no longer be 
subject to pressure from the FDA.” Am. Compl. ¶ 124. But Plaintiffs have 
continued to prescribe ivermectin to prevent or treat COVID-19 despite this 
alleged pressure. See id. ¶¶ 13, 22, 26, 29. Thus, removing the alleged pressure 
would not redress any alleged injuries. 
17 Plaintiffs also cannot show redressability regarding the earlier version of 
FDA’s article, Ex. 19, because that version has not been online since September 
2021, well before this action was filed. See Grupo Dataflux v. Atlas Glob. Grp., L.P., 
541 U.S. 567, 570–71 (2004). 
Case 3:22-cv-00184   Document 25   Filed on 08/26/22 in TXSD   Page 26 of 41

 
 
19 
 
there is no redressability where “the undoing of the governmental action will not 
undo the harm[] because the new status quo is held in place by other forces,” 
such as the knowledge and incentives of independent third parties). It is, at best, 
“speculative” whether the requested relief would redress Plaintiffs’ injuries, 
which is insufficient. Simon v. E. Ky. Welfare Rts. Org., 426 U.S. 26, 43 (1976); see El 
Paso Cnty., 982 F.3d at 341–42. 
That is especially so given that Merck, the sponsor of Stromectol® 
(ivermectin), issued a statement on February 4, 2021—more than a month before 
FDA’s article was first published—that advised against using ivermectin to 
prevent or treat COVID-19,18 and many organizations, such as the World Health 
Organization,19 have issued similar advisories. See, e.g., Ex. 12 at 6 (noting 
statements by “[the American Medical Association (“AMA”)], [the American 
Society of Health-System Pharmacists (“ASHP”)], [the Centers for Disease 
Control and Prevention (“CDC”)], FDA and Merck”); Ex. 25 (joint statement of 
the AMA, American Pharmacists Association, and ASHP, citing statements by 
CDC, FDA, the National Institutes of Health, the World Health Organization, 
Merck, and the Infectious Diseases Society of America); Am. Compl. ¶¶ 102–08. 
There is no reason to think these organizations would retract their statements if 
the Court held that the cited FDA statements exceeded FDA’s legal authority. 
Plaintiffs ask the Court to declare that the cited FDA statements “have no 
legal effect and do not bind health professionals or patients.” Am. Compl. at 44. 
 
18 See https://www.merck.com/news/merck-statement-on-ivermectin-use-
during-the-covid-19-pandemic/. 
19 See https://www.who.int/news-room/feature-stories/detail/who-
advises-that-ivermectin-only-be-used-to-treat-covid-19-within-clinical-trials.  
Case 3:22-cv-00184   Document 25   Filed on 08/26/22 in TXSD   Page 27 of 41

 
 
20 
 
But the cited statements were purely informational and did not purport to have 
any “legal effect.” See supra pp. 5–9. A declaration of what is already true would 
have “no effect” on Plaintiffs and could “not redress” their injuries. Sykes v. FEC, 
335 F. Supp. 2d 84, 92 (D.D.C. 2004) (quotations omitted). 
Finally, Plaintiffs have failed to show redressability for Marik’s and 
Bowden’s alleged injuries for two additional reasons. First, Marik’s state medical 
licenses are all expired, Ex. 10 at 10, and he has not alleged that he intends to 
renew them. Thus, the requested relief could not remedy any of his alleged 
injuries. Second, Marik and Bowden were allegedly forced to resign for reasons 
other than prescribing or promoting ivermectin to prevent or treat COVID-19. 
Marik “was forced to resign from his positions at EVMS and Sentara Norfolk 
General Hospital for promoting the use of ivermectin—as well as other safe, cheap, 
and effective off-label FDA-approved drugs—to treat COVID-19.” Am Compl. ¶ 42 
(emphasis added). And Bowden was disciplined for “using her social media 
accounts to express her personal and political opinions about the COVID-19 
vaccine and treatments.”20 The requested relief would not affect these other 
reasons for why Marik and Bowden were allegedly forced to resign and thus 
would not remedy their alleged injuries. See 15 Moore’s Federal Practice - Civil § 
101.42 (2022) (“[T]he redressability element [of Article III standing] is not 
satisfied if a favorable result would eliminate one of multiple causes of an injury 
without actually decreasing the injury at all.”).21 
 
20 https://www.nbcnews.com/news/us-news/suspended-texas-doctor-
promoted-ivermectin-covid-treatment-resigns-hos-rcna5833 (linked in Ex. 24). 
21 Even if Plaintiffs could rely on alleged injuries to independent third parties 
to support standing, they would fail to show redressability. For example, 
Plaintiffs have not shown that the requested relief would likely give the 
 
Case 3:22-cv-00184   Document 25   Filed on 08/26/22 in TXSD   Page 28 of 41

 
 
21 
 
B. Plaintiffs Have Not Shown a Waiver of Sovereign Immunity 
In a suit against the federal government, the Court lacks subject matter 
jurisdiction unless Plaintiffs show a waiver of sovereign immunity. As the Fifth 
Circuit explained, “[i]t is well settled that the United States may not be sued 
except to the extent that it has consented to suit by statute” and that, absent such 
consent, “the court lacks jurisdiction.” Alabama-Coushatta, 757 F.3d at 488–89 
(quotations omitted). Waivers of sovereign immunity are “strictly construed” in 
favor of the government. Lane v. Pena, 518 U.S. 187, 192 (1996). 
Plaintiffs assert both a nonstatutory cause of action (Count I) and APA 
causes of action (Counts II–IV).22 Fifth Circuit precedent establishes that the 
APA, 5 U.S.C. § 702, waives sovereign immunity for nonstatutory and APA 
causes of action only where there is “agency action” and the plaintiff has 
“suffered legal wrong because of the challenged agency action, or is adversely 
affected or aggrieved by that action within the meaning of a relevant statute.” 
Alabama-Coushatta, 757 F.3d at 488–89; see Walmart Inc. v. U.S. Dep’t of Just., 21 
F.4th 300, 310–11 (5th Cir. 2021) (suit barred by sovereign immunity because 
plaintiff did not show “agency action”); Louisiana v. United States, 948 F.3d 317, 
322 (5th Cir. 2020). For APA causes of action, the sovereign immunity waiver 
also requires “final agency action.” Alabama-Coushatta, 757 F.3d at 488–89 
(explaining that the finality requirement of 5 U.S.C. § 704 “has been read into § 
 
pharmacies that allegedly refused to fill patients’ ivermectin prescriptions or the 
insurance companies that allegedly refused to pay for those prescriptions any 
reason to reconsider those decisions. See Renal Physicians, 489 F.3d at 1278. 
22 Count V seeks a declaratory judgment based on Counts I–IV. Am. Compl. 
¶¶ 157–59. 
Case 3:22-cv-00184   Document 25   Filed on 08/26/22 in TXSD   Page 29 of 41

 
 
22 
 
702” for APA claims); see also Sierra Club v. Peterson, 228 F.3d 559, 569 (5th Cir. 
2000) (en banc); Qureshi v. Holder, 663 F.3d 778, 781 (5th Cir. 2011). 
The cited FDA statements are not “agency action” because they are not “the 
whole or part of an agency rule, order, license, sanction, relief, or the equivalent 
or denial thereof, or failure to act.” 5 U.S.C. § 551(13). Instead, they were “purely 
informational.” Sprint Nextel Corp. v. FCC, 508 F.3d 1129, 1132 (D.C. Cir. 2007) 
(“purely informational” press release was not reviewable agency action). The 
cited statements simply communicated FDA’s views about the risks of using 
ivermectin to prevent or treat COVID-19 and its nonbinding advice that 
consumers “should not use ivermectin” for that purpose (not “may not” or “must 
not”). Ex. 1 at 2 (emphasis added); see Ex. 2 at 2; Ex. 3 at 2; Ex. 4 at 2; Ex. 6 at 2; 
Ex. 7 at 2; Ex. 19 at 2; Ex. 22 at 2. As the Amended Complaint implicitly concedes, 
the cited statements “discourag[ed],” but did not prohibit, “the use of ivermectin 
to treat or prevent COVID-19.” Am. Compl. ¶ 86. The September 2021 article and 
April 2020 FAQ also encouraged consumers to follow their doctors’ advice: “[i]f 
your health care provider writes you an ivermectin prescription, fill it through a 
legitimate source such as a pharmacy, and take it exactly as prescribed.” Ex. 1 at 
3; see also Ex. 2 at 2. The article also recommended that consumers “[t]alk to your 
health care provider about available COVID-19 vaccines and treatment options” 
because “[y]our provider can help determine the best option for you, based on your 
health history.” Ex. 1 at 4 (emphasis added). 
The language of the cited tweets and Instagram post does not make them 
“agency action.” The cited August 2021 tweet stated, “You are not a horse. You 
are not a cow. Seriously, y’all. Stop it,” Ex. 4 at 2, and the cited Instagram post 
Case 3:22-cv-00184   Document 25   Filed on 08/26/22 in TXSD   Page 30 of 41

 
 
23 
 
from the same day stated, “You are not a horse. Stop it with the #ivermectin. It’s 
not authorized for treating #COVID,” Ex. 6 at 2. The cited April 2022 tweet 
stated, “Hold your horses, y’all. Ivermectin may be trending, but it still isn’t 
authorized or approved to treat COVID-19,” Ex. 7 at 2. Plaintiffs do not plausibly 
allege that anyone would have understood the informal language in the cited 
tweets and Instagram post to be “order[s],” 5 U.S.C. § 551(13), prohibiting the use 
of ivermectin to prevent or treat COVID-19. Moreover, FDA’s “Stop it” and 
“Hold your horses” statements plainly referred to taking animal-use ivermectin, 
especially given that both tweets and the Instagram post included images of 
horses. See Exs. 4, 6–7. Plaintiffs do not allege that they prescribe or promote 
animal-use ivermectin for human use, nor that doing so would fall within the 
“practice of medicine.” Am. Compl. ¶ 1 (alleging that FDA “generally cannot 
ban” off-label “uses of [approved] human drugs”). And both tweets linked to the 
cited article,23 which included an image of a horse and explained that it was 
prompted by “multiple reports of patients who have required medical attention, 
including hospitalization, after self-medicating with ivermectin intended for 
livestock.” Ex. 1 at 2–3; see Ex. 19 at 2. The cited article also advised consumers to 
fill an ivermectin prescription “through a legitimate source such as a pharmacy, 
and take it exactly as prescribed.” Ex. 1 at 3; see Ex. 19 at 3. 
The cited FDA statements do not meet the definition of any action included 
in the definition of “agency action.” 5 U.S.C. § 551(13). For example, they are not 
an “order” because they are not “a final disposition,” formulated through an 
FDA “adjudication” process, that “ha[s] some determinate consequences” for 
 
23 The August 21, 2021, tweet initially linked to the original version of the 
article and then linked to the new version once it went live in September 2021. 
Case 3:22-cv-00184   Document 25   Filed on 08/26/22 in TXSD   Page 31 of 41

 
 
24 
 
Plaintiffs. 5 U.S.C. § 551(6)–(7); Int’l Tel. & Tel. Corp. v. Loc. 134, Int’l Bhd. of Elec. 
Workers, 419 U.S. 428, 443 (1975). They did “not order anybody to do anything,” 
and “standing alone, [they bound] no one.” Int’l Tel. & Tel., 419 U.S. at 443 
(quotation omitted). Nor are the cited statements a “sanction” because there is no 
indication that FDA was “intent on penalizing [Plaintiffs] through adverse 
publicity.” Indus. Safety Equip. Ass’n v. EPA, 837 F.2d 1115, 1119, 1121 (D.C. Cir. 
1988); see 5 U.S.C. § 551(10). Nor are they a “rule” because they did not purport 
to bind FDA or anyone else. See 5 U.S.C. § 551(4); Amoco Prod. Co. v. Watson, 410 
F.3d 722, 732 (D.C. Cir. 2005) (Roberts, J.), aff’d sub nom. BP Am. Prod. Co. v. 
Burton, 549 U.S. 84 (2006). 
In addition to failing to show that the cited FDA statements are “agency 
action,” Plaintiffs failed to show that they “suffered legal wrong because of” the 
cited statements. Alabama-Coushatta, 757 F.3d at 488–89; see supra pp. 12–17. For 
this reason as well, Plaintiffs have not shown a waiver of sovereign immunity 
under the APA. See Alabama-Coushatta, 757 F.3d at 488–89. 
Furthermore, even if Plaintiffs had shown that the cited FDA statements are 
“agency action,” there would be no waiver of sovereign immunity for Plaintiffs’ 
APA claims because the statements are not “final.” They did not mark the 
“consummation” of FDA’s decisionmaking process regarding the use of 
ivermectin to prevent or treat COVID-19. Bennett v. Spear, 520 U.S. 154, 177–78 
(1997) (quotations omitted). Instead, they presented FDA’s tentative 
recommendations based on “[c]urrently available data,” while explaining that 
“[a]dditional testing is needed” and that “[c]linical trials” are “ongoing.” Ex. 1 at 
Case 3:22-cv-00184   Document 25   Filed on 08/26/22 in TXSD   Page 32 of 41

 
 
25 
 
3; Ex. 2 at 2; see also Ex. 19 at 3 (noting that “initial research is underway”); 
Bennett, 520 U.S. at 177–78.  
The cited FDA statements also were not actions “by which rights or 
obligations have been determined, or from which legal consequences will 
flow.” Bennett, 520 U.S. at 178 (quotations omitted); Qureshi, 663 F.3d at 781; see 
La. State v. U.S. Army Corps of Eng’rs, 834 F.3d 574, 580–81 (5th Cir. 2016). Instead, 
they were “purely informational in nature; [they] imposed no obligations and 
denied no relief”; and “[c]ompelling no one to do anything, [they] had no 
binding effect whatsoever.” Indep. Equip. Dealers Ass’n v. EPA, 372 F.3d 420, 427 
(D.C. Cir. 2004) (Roberts, J.); see Barry v. SEC, No. 10-cv-4071, 2012 WL 760456, at 
*6 (E.D.N.Y. Mar. 7, 2012) (press release was not final agency action because it 
did not determine any “rights or obligations” or have any “legal consequences”). 
Even if the cited FDA statements “put pressure” on Plaintiffs, that would not 
show final agency action because “any such consequences are practical, as 
opposed to legal, ones.” La. State, 834 F.3d at 583. 
It is well established that FDA warning letters, which are posted on FDA’s 
website, are not “final agency action” because, like the cited FDA statements, 
they are “informal and advisory” communications about FDA’s “position on a 
matter” and do not “compel[] action” by anyone. Holistic Candlers & Consumers 
Ass’n v. FDA, 664 F.3d 940, 944 (D.C. Cir. 2012); see also Swisher Int’l, Inc. v. FDA, 
No. 21-13088, 2022 WL 320889, at *5 (11th Cir. Feb. 3, 2022); Cody Labs., Inc. v. 
Sebelius, 446 F. App’x 964, 969 (10th Cir. 2011); cf. Am. Paper Inst., Inc. v. EPA, 882 
F.2d 287, 289 (7th Cir. 1989); Dow Chem. v. EPA, 832 F.2d 319, 324 (5th Cir. 1987). 
It is even clearer that the cited FDA statements are not final agency action 
Case 3:22-cv-00184   Document 25   Filed on 08/26/22 in TXSD   Page 33 of 41

 
 
26 
 
because, unlike warning letters, they were not directed at particular entities and 
did not allege violations of law.  
It is not enough for agency conduct to affect the plaintiffs indirectly by 
influencing independent third parties; instead, final agency action must “directly 
affect” the plaintiffs. Franklin v. Massachusetts, 505 U.S. 788, 797 (1992). In 
Franklin, the Court held that an agency report was not “final agency action” 
because it “carrie[d] no direct consequences” and “serve[d] more like a tentative 
recommendation than a final and binding determination.” Id. at 797–98; see 
Dalton v. Specter, 511 U.S. 462, 469–70 (1994). Here, similarly, the cited FDA 
statements “carrie[d] no direct consequences” for Plaintiffs, but instead provided 
nonbinding “recommendations” to consumers about the use of ivermectin to 
prevent or treat COVID-19. Franklin, 505 U.S. at 798. The actions that directly 
affected Plaintiffs were the actions of independent third parties such as their 
employers and patients. Even if the cited FDA statements were “persuasive” to 
these independent third parties and “made business more difficult” for Plaintiffs, 
such an “indirect effect” on Plaintiffs from independent third parties is “not a 
regulatory effect reviewable in court.” Invention Submission Corp. v. Rogan, 357 
F.3d 452, 459–60 (4th Cir. 2004) (citing Flue-Cured Tobacco Coop. Stabilization Corp. 
v. EPA, 313 F.3d 852, 861 (4th Cir. 2002)).24 Moreover, even assuming arguendo 
that Plaintiffs could assert their patients’ injuries, the actions that directly 
 
24 The Fourth Circuit explained: “We do not think that Congress intended to 
create private rights of actions to challenge the inevitable objectionable 
impressions created whenever controversial research by a federal agency is 
published. Such policy statements are properly challenged through the political 
process and not the courts.” Invention Submission, 357 F.3d at 459 (quoting Flue-
Cured Tobacco, 313 F.3d at 861) (internal quotation marks omitted). 
Case 3:22-cv-00184   Document 25   Filed on 08/26/22 in TXSD   Page 34 of 41

 
 
27 
 
affected their patients were the actions of independent third parties such as 
pharmacies and insurance companies.  
Plaintiffs assert that “legally binding effects are not necessary to render an 
agency action ‘final’ for purposes of judicial review when the action in question 
is prohibited by statute regardless of such effects.” Am. Compl. ¶ 139. But even if 
that were true, Plaintiffs still have not shown that the cited FDA statements are 
“agency action” in the first place. Plaintiffs also assert that “[s]tatements with the 
false imprimatur of authority, intended to stop non-conforming practice and be 
interpreted by the public as authoritative, have the effect of determining rights 
and obligations, or otherwise resulting in legal consequences.” Id. ¶ 138. But the 
cited statements purported to provide only recommendations about what people 
“should” do, e.g., Ex. 1 at 2; Ex. 2 at 2; Ex. 3 at 2; they did not purport to create 
any rights or obligations or have any legal consequences, and there is no 
indication that FDA intended to convey that they did. See Bennett, 520 U.S. at 178; 
Qureshi, 663 F.3d at 781.  
Although Plaintiffs allege that FDA’s “statements are regularly relied on to 
establish the appropriate standard of care and dictate the practice of medicine,” 
Am. Compl. ¶ 138, the cited FDA statements made clear that doctors retain 
discretion to prescribe ivermectin to prevent or treat COVID-19. See, e.g., Ex. 1 at 
3–4; Ex. 2 at 2. And in any event, any “indirect effects” from independent third 
parties that were persuaded by the cited FDA statements do not make those 
statements final agency action. See Invention Submission, 357 F.3d at 459–60. 
In sum, Plaintiffs have failed to show a waiver of sovereign immunity for 
any of their causes of action because the cited FDA statements are not agency 
Case 3:22-cv-00184   Document 25   Filed on 08/26/22 in TXSD   Page 35 of 41

 
 
28 
 
action, let alone final agency action. See Alabama-Coushatta, 757 F.3d at 488–89. 
Thus, the court lacks jurisdiction and the action must be dismissed. See id. 
II. The Amended Complaint Fails to State a Plausible Claim for Relief 
If the Court were to find that one or more of the cited statements were final 
agency action—which Defendants do not concede—the Amended Complaint 
should be dismissed under Rule 12(b)(6) because it does not contain “sufficient 
factual material, accepted as true, to state a claim to relief that is plausible on its 
face.” Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009) (quotation omitted). All of 
Plaintiffs’ claims, including their APA claims and ultra vires claim, are entirely 
premised on arguments raised for the first time before this Court. By failing to 
present their arguments to FDA, Plaintiffs forfeited them, thus depriving their 
claims of any plausible legal basis. 
The long-standing rule of “issue exhaustion . . . require[s] parties to give the 
agency an opportunity to address an issue before seeking judicial review of that 
question.” Carr v. Saul, 141 S. Ct. 1352, 1358 (2021); see United States v. L.A. Tucker 
Truck Lines, Inc., 344 U.S. 33, 37 (1952); Adamski v. McHugh, 304 F. Supp. 3d 277, 
236–39 (D.D.C. 2015). A court “will not ordinarily consider arguments that a 
litigant could have raised before an agency but chose not to.” Palm Valley Health 
Care, Inc. v. Azar, 947 F.3d 321, 327 (5th Cir. 2020) (citation omitted). 
Requiring litigants to raise their arguments before the agency in the first 
instance “ensures simple fairness to the agency” and provides for a “full airing of 
the issues before the agency” prior to litigation. Id. Presenting arguments to the 
agency gives it “the opportunity to correct its own errors” and “produce a useful 
record for subsequent judicial consideration.” McCarthy v. Madigan, 503 U.S. 140, 
Case 3:22-cv-00184   Document 25   Filed on 08/26/22 in TXSD   Page 36 of 41

 
 
29 
 
145–46 (1992). Moreover, agency actions are frequently of a discretionary nature 
or require expertise, and “the agency should be given the first chance to exercise 
that discretion or to apply that expertise.” McKart v. United States, 395 U.S. 185, 
194 (1969). The issue exhaustion requirement is “analog[ous] to the rule that 
appellate courts will not consider arguments not raised before trial courts.” Sims 
v. Apfel, 530 U.S. 103, 108–09 (2000). As in an appellate court, the “focal point” for 
review under the APA “should be the administrative record already in existence, 
not some new record made initially in the reviewing court.” Camp v. Pitts, 411 
U.S. 138, 142 (1973). An agency’s decision is not “arbitrary and capricious in 
failing to identify, raise, and resolve sua sponte an issue never presented” to the 
agency. Fleming v. U.S. Dep’t of Agric., 987 F.3d 1093, 1100 (D.C. Cir. 2021). 
In Palm Valley Health Care v. Azar, for example, the plaintiff sought 
administrative review of a Medicare overpayment finding regarding home 
health care coverage. 947 F.3d at 324. Despite having “many opportunities” to 
raise its arguments with the agency, the plaintiff ultimately advanced an 
argument in court that it had never presented to the agency: that the agency had 
applied the wrong definition of the term “homebound.” Id. at 325, 327. The Court 
of Appeals affirmed the district court’s dismissal of that count because the 
plaintiff “failed to exhaust its challenge to the ‘homebound’ standard.” Id. at 328. 
As in Palm Valley Health Care, Plaintiffs failed to raise their arguments with 
FDA despite having the opportunity to do so. For example, Plaintiffs 
acknowledge that the cited FDA article states, “[i]f your health care provider 
writes you an ivermectin prescription, fill it through a legitimate source such as a 
pharmacy, and take it exactly as prescribed,” but object that that this statement 
Case 3:22-cv-00184   Document 25   Filed on 08/26/22 in TXSD   Page 37 of 41

 
 
30 
 
“is buried in the middle of the document and does not influence the effect of the 
title,” which they contend “discourage[s] the use of ivermectin to treat or prevent 
COVID-19.” Am. Compl. ¶ 86. Plaintiffs similarly make a variety of arguments 
about ivermectin and contend that the cited FDA statements were arbitrary and 
capricious because the agency “fail[ed] to address or respond to any of the 
scientific evidence showing that ivermectin is an effective prophylactic or acute 
treatment for COVID-19.” Id. ¶¶ 73, 76–77, 80–81, 132–44. Plaintiffs also argue 
that FDA lacked authority to make the challenged statements at all. See id. 
¶¶ 129–31, 145–56. Plaintiffs could have presented their arguments to FDA 
through a Citizen Petition.25 That process allows any “interested person [to] 
petition the Commissioner to . . . take or refrain from taking any . . . form of 
administrative action” by filing a Citizen Petition. 21 C.F.R. § 10.25(a); see id. 
§ 10.30; see also id. § 10.45. Plaintiffs did not file a Citizen Petition and do not 
allege that their arguments were raised with FDA through any other method. 
Thus, even if the Court were to find that Plaintiffs challenge final agency action, 
they forfeited their ability to raise their arguments in this case by not first raising 
them with FDA. Because Plaintiffs’ arguments “cannot [be] consider[ed]” by the 
Court, their claims should be dismissed. Palm Valley Health Care, 947 F.3d at 327. 
CONCLUSION 
For the foregoing reasons, the Amended Complaint should be dismissed for 
lack of subject matter jurisdiction or, in the alternative, for failure to state a claim. 
 
25 Plaintiffs remain free to present their arguments to FDA through a Citizen 
Petition (or some other method). 
Case 3:22-cv-00184   Document 25   Filed on 08/26/22 in TXSD   Page 38 of 41

 
 
31 
 
 
August 26, 2022 
 
 
 
 
Respectfully submitted, 
 
  
 
 
 
 
 
/s/ Isaac C. Belfer 
  
 
 
 
 
 
ISAAC C. BELFER 
Attorney-In-Charge  
D.C. Bar No. 1014909 
 
OLIVER MCDONALD 
Of Counsel  
N.Y. Bar No. 5416789 
  
 
 
 
 
 
Trial Attorneys 
  
 
 
 
 
 
Consumer Protection Branch 
  
 
 
 
 
 
Civil Division 
  
 
 
 
 
 
U.S. Department of Justice 
  
 
 
 
 
 
PO Box 386 
  
 
 
 
 
 
Washington, DC  20044-0386 
  
 
 
 
 
 
(202) 305-7134 (Belfer) 
 
(202) 305-0168 
  
 
 
 
 
 
(202) 514-8742 (fax) 
  
 
 
 
 
 
Isaac.C.Belfer@usdoj.gov 
 
Oliver.J.McDonald@usdoj.gov 
 
 
 
Counsel for Defendants 
Case 3:22-cv-00184   Document 25   Filed on 08/26/22 in TXSD   Page 39 of 41

 
 
 
CERTIFICATE OF CONFERENCE 
On August 2, 2022, pursuant to Rule 6 of the Rules of Practice of the 
Galveston Division of the U.S. District Court for the Southern District of Texas, 
Defendants’ counsel sent Plaintiffs’ counsel a letter stating the bases for their 
intended motion to dismiss and informing Plaintiffs of their right to amend their 
Complaint within 14 days. On August 4, 2022, the parties met and conferred 
regarding Defendants’ intended motion to dismiss. On August 8, 2022, Plaintiffs 
filed their Amended Complaint, ECF No. 12, which Defendants now move to 
dismiss.  
 
August 26, 2022 
 
 
 
/s/ Isaac C. Belfer 
  
 
 
 
 
 
Isaac C. Belfer 
 
 
Case 3:22-cv-00184   Document 25   Filed on 08/26/22 in TXSD   Page 40 of 41

 
 
2 
 
CERTIFICATE OF SERVICE 
I hereby certify that this document, filed through the CM/ECF system, will 
be sent via electronic mail to the registered participants as identified on the 
Notice of Electronic Filing. 
 
August 26, 2022 
 
 
 
/s/ Isaac C. Belfer 
  
 
 
 
 
 
Isaac C. Belfer 
 
Case 3:22-cv-00184   Document 25   Filed on 08/26/22 in TXSD   Page 41 of 41

File and source

File
gov.uscourts.txsd.1875135.25.0.pdf
Size
211,866 bytes
SHA-256
1abebf23e4aac86ef976ea5b0728a839c3dca5d7b916be444fd8c34abfcf4e6d
Our copy
gov.uscourts.txsd.1875135.25.0.pdf
Original
archive.org
Back to top