Complaint Against All Defendants , Filed by Michael Dilworth. (Attachments: # 1 Civil Cover Sheet, # 2 Designation Form)(SCHREIBER, David)

Document #1 Filed 03/30/2026 · 65 pages · District Court, E.D. Pennsylvania · View original PDF

JURISDICTION AND VENUE

1Jurisdiction exists in this action under diversity of citizenship, 28 U.S.C. §1332, as the matter in controversy exceeds One Hundred and Fifty-Thousand Dollars ($150,000), exclusive of interest and costs and as Plaintiff is a citizen of the Commonwealth of Pennsylvania, and each Defendant is neither incorporated nor has its principal place of business in the Commonwealth of Pennsylvania.

2Venue is appropriate in this Judicial District via 28 U.S.C. §1391 because substantial, material events, acts/omissions/commissions occurred within the Eastern District of Pennsylvania, including: the marketing, prescription, and sale of Ozempic (also known as Semaglutide) to Plaintiff Michael Dilworth, and the injury to Plaintiff Michael Dilworth (who resides within the Eastern District of Pennsylvania); in addition, the Eastern District of Pennsylvania is the venue for MDL 3163 litigation.

3This Court has personal jurisdiction over Defendants consistent with the United States Constitution and 42 Pa. C.S. §5322 (Pennsylvania’s “long arm” statute), as Plaintiff’s claims arise out of Defendants’ transaction of business, their tortious acts within the Commonwealth of Pennsylvania, their doing a series of similar acts for the purpose of thereby realizing pecuniary benefit, and by virtue of Defendants’ substantial, continuous, and systematic contacts with the Commonwealth of Pennsylvania.

4This Court has supplemental jurisdiction over the remaining common law and state law claims pursuant to 28 U.S.C. § 1367.

5.Venue is further proper under 28 U.S.C. § 1391(b)(2) as a substantial part of the events or omissions giving rise to the claim occurred in this District. Defendants routinely market their products at issue in this District, including here to Plaintiff Michael Dilworth and his prescribing Doctor, and conduct business in this District related to their products at issue in the Eastern District of Pennsylvania.

6Novo Nordisk’s additional contacts with Philadelphia, Pennsylvania include the following, which are related to the actions and transactions at issue in this complaint:

7Novo Nordisk has retained U.S. private contract manufacturer PCI Pharma Services to handle assembly and packaging of its products, including putting together the self-injection pens used to administer its products; and, the self-injection pens are required for a patient to use the drug and potentially suffer adverse effects underlying this Complaint; and, PCI Pharma Services is headquartered in Philadelphia, PA.1

8Novo Nordisk routinely recruits employees within Philadelphia related to diabetes care, and recruits sales associates in Pennsylvania; and, Novo Nordisk maintains employees in 1 https://www.nytimes.com/2023/08/17/health/weight-loss-drugs-obesity-ozempic-wegovy.html Philadelphia related to diabetes care; and, the Philadelphia Department of Public Health released a report on “Drug Marketing Through Gifts of Meals to Physicians in Philadelphia,” which showed Novo Nordisk’s Ozempic was #8 in the “Top 20 Drugs Marketed in Philadelphia” in 2018 through February 2020.2

THE PARTIES

9At all times pertinent hereto, Plaintiff Michael Dilworth (hereinafter sometimes “Plaintiff”) is an adult resident and citizen of the Commonwealth of Pennsylvania residing at 12 West 6th Street, Bridgeport, Pennsylvania 19405.

10Novo Nordisk Inc. (“Novo Nordisk”) is a Delaware corporation that has its principal place of business at 800 Scudders Mill Road, Plainsboro, New Jersey 08536.

11Defendant Novo Nordisk A/S is a public limited liability company organized under the laws of Denmark with a principal place of business in Bagsvaerd, Denmark.

12Defendant Novo Nordisk A/S and its subsidiaries are collectively referred to as “the Novo Nordisk Defendants” and “Novo Nordisk”.

BACKGROUND AND INTRODUCTION

13This is an action for damages suffered by Plaintiff, who was severely injured as a result of his prescribed use of Ozempic/Semaglutide, a GLP-1 receptor agonist (“GLP-1RA”), a prescription medication designed, researched, tested, manufactured, marketed, supplied, promoted, advertised, packaged, labeled, sold and/or distributed by Defendants.

14Ozempic belongs to a class of drugs called GLP-1 receptor agonists (“GLP-1RAs”), and the active ingredient in Ozempic is known as Semaglutide, the same as Wegovy (both 2 https://www.phila.gov/media/20200204150030/2020-drug-marketing-report_2_4_2020.pdf Ozempic and Wegovy are Semaglutide and are both designed, researched, tested, manufactured, marketed, supplied promoted, advertised, packaged, labeled sold and/or distributed by Defendants).

15Medications within the GLP-1RA class of drugs mimic the activities of physiologic GLP-1, a gut hormone that binds to receptors throughout the body and, notably, activates GLP-1 receptors in the pancreas to stimulate the release of insulin and suppress glucagon.

16GLP-1 RAs are designed to work similarly, to stimulate insulin production and reduce glucose production, but engineered to last longer than naturally occurring GLP-1, which has a short life and is quickly metabolized by enzymes.

17GLP-1 RAs are prescribed, for certain patient populations, to control blood sugar in adults with type 2 diabetes, reduce cardiac risk, and/or aid in chronic weight management.

18Defendants have failed to provide adequate warnings about adverse events caused by their GLP-1RAs, even serious and devastating effects, including non-arteritic anterior ischemic optic neuropathy (“NAION”), which can result in blindness and permanent vision loss, as well as blurry and/or darkened vision, which may lead to falls and other injuries.

19The decision to target the American population for the sale of Defendants’ GLP1RAs was no6t accidental whereby Defendants understood the vast financial potential of marketing medications for weight loss in the United States, where obesity rates were on the rise despite the culture’s obsession with losing weight and being thin.

20Defendants set upon a course to create and expand the market for weight-loss medication(s) by, among other things, advocating for obesity to be classified as a disease and thereby expanding the market for their drugs, including Ozempic, spending hundreds of millions of dollars in an effort to change the medical consensus on how to treat obesity, implementing

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