Full opinion text
OPINION SMITH, Chief Judge. This opinion addresses two sets of consolidated appeals concerning two pharmaceutical drugs: Lipitor and Effexor XR. In both sets of consolidated appeals, plaintiffs allege that the companies holding the patents related to Lipitor and Effexor XR fraudulently procured and enforced certain of those patents. Plaintiffs further allege that those companies holding the patents entered into unlawful, monopolistic settlement agreements with potential manufacturers of generic versions of Lipitor and Effexor XR. The same District Court Judge dismissed the complaints in the Lip-itor litigation and dismissed certain allegations in the Effexor litigation. Those decisions relied on plausibility determinations that are now challenged on appeal. We begin with a brief summary of the relevant regulatory scheme applicable to pharmaceutical drugs and then detail the factual and procedural backgrounds of these two sets of consolidated appeals. The remainder of the opinion broadly covers two issues. First, in F.T.C. v. Actavis, Inc., 570 U.S. 136, 133 S.Ct. 2223, 186 L.Ed.2d 343 (2013), the Supreme Court concluded that payments from patentees to infringers through “reverse payment settlement agreements” are subject to antitrust scrutiny. Id. at 2227. In both sets of consolidated appeals, plaintiffs allege that the companies holding the pharmaceutical patents and the generic manufacturers entered into such agreements. We are asked to decide whether those allegations are plausible. We conclude, as to both sets of appeals, that they are. Second, regarding only the Lipitor consolidated appeals, we address whether plaintiffs in those appeals pled plausible allegations of fraudulent patent procurement and enforcement, as well as other related misconduct. We again determine that those allegations are indeed plausible. Accordingly, we will reverse the District Court’s dismissal of the complaints in the Lipitor litigation, reverse its dismissal of the allegations in the Effe-xor litigation, and remand for further proceedings. I The 1984 Drug Price Competition and Patent Term Restoration Act (the “Hatch-Waxman Act”), 98 Stat. 1585, as amended,, provides a regulatory framework designed in part to, (1) ensure that only rigorously tested pharmaceutical drugs are marketed to the consuming public, (2) in-centivize drug manufactui'ers to. invest in new research and development, and (3) encourage generic drug entry, into the marketplace. As we have noted previously, the Hatch-Waxman Act contains four key relevant features. See In re Lipitor Antitrust Litig., 855 F.3d 126, 135 (3d Cir. 2017) (Lipitor III), as amended (Apr. 19, 2017); King Drug Co. of Florence v. Smithkline Beecham Corp., 791 F.3d 388, 394 (3d Cir. 2015), cert. denied, — U.S. -, 137 S.Ct. 446, 196 L.Ed.2d 328 (2016). First, the Hatch-Waxman Act requires á drug manufacturer wishing to market a new brand-name drug to first submit a New Drug Application (“NDA”) to the Food and Drug Administration (“FDA”), see 21 U.S.C. § 355, and then undergo a long, complex, and costly testing process, see 21 U.S.C. § 355(b)(1). (requiring, among other things, “full reports of investigations” into safety and effectiveness; “a full list of the articles used as components”; and a “full description” of how the drug is manufactured, processed, and packed). If this process is successful, the FDA may grant the drug manufacturer approval to market the brand-name , drug. Second, after that approval, a generic manufacturer can obtain similar approval by submitting an Abbreviated New Drug Application (“ANDA”) that “shows that the generic drug has.the same active ingredients as, and is biologically equivalent to, the brand-name drug.” Caraco Pharm. Labs., Ltd. v. Novo Nordisk A/S, 566 U.S. 399, 405, 132 S.Ct. 1670, 182 L.Ed.2d 678 (2012) (citing 21 U.S.C. §§ 355(j)(2)(A)(ii), (iv)),. This way, a generic manufacturer does not need to undergo the same costly approval procedures to develop a drug that has already received FDA approval. Actavis, 133 S.Ct. at 2228 (“The Hatch-Wax-man process, by allowing the, generic to piggy-back on the pioneer’s approval efforts, ‘speed[s],the introduction of low-cost generic drugs , to market. Caraco, [566 U.S. at 405, 132 S.Ct. 1670], thereby furthering drug competition.” (first alteration in original)). Third, foreseeing the potential for conflict between brand-name and generic drug manufacturers, the Hatch-Waxman Act “sets forth special procedures for identifying, and resolving, related patent disputes.” Id. The Hatch-Waxman Act, as well as federal regulations, requires brand-name drug manufacturers to file information about'their patents with their NDA, Id. The brand-name manufacturer “is required to list any patents issued relating to the drug’s composition or methods of use.” Lipitor III, 855 F.3d at 135. That filing must include the patent number and expiration date of the patent. See Caraco, 566 U.S. at 405, 132 S.Ct. 1670 (quoting 21 U.S.C. § 355(b)(1)). Upon approval of the brand-name manufacturer’s NDA, the FDA publishes the submitted patent information in its “Orange Book,” more formally known as the Approved Drug Products with Therapeutic Equivalence Evaluations. Id. at 405-06, 132 S.Ct. 1670. Once a patent has been listed in the Orange Book, the generic manufacturer is free to file an ANDA if it can certify that its proposed generic drug will not actually violate the brand manufacturer’s patents. Id. at 405, 132 S.Ct. 1670; see also id. (The FDA “cannot authorize a generic drug that would infringe a patent.”). A generic manufacturer’s ANDA certification may, state: (I) that such patent information has not been filed, (II) that such patent has expired, (III) ... the date on which such patent will expire, or (IV) that such patent is invalid or will not be infringed by the manufacture, use, or sale of the new drug for which the application is submitted. 21 U.S.C. § 355(j)(2)(A)(vii). “The ‘paragraph IV’ route[ ], automatically counts as patent infringement .... ” Actavis, 133 S.Ct. at 2228 (citing 35 U.S.C. § 271(e)(2)(A)). As a result, a paragraph IV certification often “means provoking litigation” instituted by the brand manufacturer. Caraco, 566 U.S. at 407, 132 S.Ct. 1670. If the brand-name manufacturer initiates a patent infringement suit within 45 days of the ANDÁ filing, the FDA must withhold approval of the generic for at least 30 months while the parties litigate the validity or infringement of the patent. Actavis, 133 S.Ct. at 2228 (citing 21 U.S.C. § 355(j) (5) (B) (iii)). If a court decides the infringement claim within this 30-month period, then the FDA will follow that determination. Id. However, if the litigation is still proceeding at the end of the 30-month period, the FDA may give its approval to the generic drug manufacturer to begin marketing a generic version of the drug. Id. The generic manufacturer then has the option to launch “at risk,” meaning that, if the ongoing court proceeding ultimately determines that the patent was valid and infringed, the generic manufacturer will be liable for the brand-name manufacturer’s lost profits despite the FDA’s approval. See King Drug Co., 791 F.3d at 396 n.8. Fourth; to incentivize generic drug manufacturers to file an ANDA challenging weak patents, the Hatch-Waxman Act provides that the first generic manufacturer to file'- a paragraph IV certification will enjoy a 180-day exclusivity period. 21 U.S.C. § .355(j)(5)(B)(iv). This exclusivity period prevents any other generic from competing with the brand-name drug, see Actavis, 133 S.Ct. at 2229, which .is an opportunity that can be “worth several hundred million dollars,” to the first-ANDA filer, id. (quoting C. Scott Hemphill, Paying for Delay: Pharmaceutical Patent Settlement as a Regulatory Design Problem, 81 N.Y.U. L. Rev. 1553, 1579 (2006)). This 180-day exclusivity period belongs only to the first generic manufacturer to file-an ANDA; if the first-ANDA filer forfeits its exclusivity rights, no other generic-manufacturer is entitled to it. Id. (citing 21 U.S.C. § 355(j)(5)(D)). Importantly, .the- brand-name manufacturer is not barred from entering the generic market with its own generic version of the drug — a so-called “authorized generic”— during the 180-day exclusivity period. See Lipitor III, 855 F.3d at 135-36 (citing cases). ... II These consolidated appeals concerning Lipitor and Effexor XR involve antitrust challenges related to that pharmaceutical regulatory scheme. This panel previously detailed much -of the factual background and procedural history of these appeals. See Lipitor III, 855 F.3d at 136-42. In relevant part, we repeat and expand on much of that earlier recitation. A In In re Lipitor Antitrust Litigation, Nos. 14-1402 et al., plaintiffs are a putative class of direct purchasers of branded Lipitor, a putative class of end payors, and several individual retailers asserting direct-purchaser claims. We will refer to these plaintiffs collectively as the “Lipitor plaintiffs.” Defendants are Pfizer Inc., Ranbaxy Inc., and their respective corporate affiliates; they will be referred to collectively as the “Lipitor defendants.” We proceed by outlining the factual background behind those consolidated appeals and then describing their procedural history. 1 Lipitor is a brand-name drug designed to reduce the level of LDL cholesterol in the bloodstream. In 1987, the U.S. Patent and Trademark Office (PTO) granted Pfizer the original patent for Lipitor. That patent — designated U.S. Patent No. 4,681,-893 (the ’893 Patent) — claimed protection for atorvastatin, Lipitor’s active ingredient. Although initially set to expire on May 30, 2006, the ’893 patent received an extension from the FDA, lengthening the patent’s term through March 24,2010. Pfizer obtained additional, follow-on patent protection for Lipitor in December 1993 when the PTO issued U.S. Patent No. 5,273,995 (the ’995 Patent). That patent claimed protection for atorvastatin calcium, the specific salt form of the active atorvastatin molecule in Lipitor. Lipitor plaintiffs assert that Pfizer committed fraud in the procurement and enforcement of the ’995 Patent. They allege that Pfizer submitted false and misleading data to the PTO to support its claim that the cholesterol-synthesis inhibiting activity of ator-vastatin calcium was surprising and unexpected. Specifically, Lipitor plaintiffs claim that Pfizer chemists informed senior management that the ’893 Patent already covered atorvastatin calcium; Pfizer produced a misleading chart and other data, purportedly cherry-picked, to support its claim that atorvastatin calcium was several times more effective than expected; and, in order to avoid undermining its claim of surprising results, Pfizer intentionally withheld another dataset that contradicted its claim as to the surprising effectiveness of atorvastatin calcium. The PTO originally denied the patent application for atorvasta-tin calcium as “anticipated” by the ’893 Patent. In response, Pfizer submitted a declaration from one of its chemists claiming even greater, i.e., more surprising, results from testing atorvastatin calcium. The PTO again rejected the patent application for atorvastatin calcium based on its contents being covered by the ’893 Patent. Pfizer appealed that determination to the PTO’s Patent Trial and Appeal Board (PTAB). The PTAB reversed the rejection of Pfizer’s patent application, concluding that the application was not anticipated by the ’893 Patent. It, however, required further proceedings on Pfizer’s application, noting that “[a]n obviousness rejection ... appeared] to be in order.” Lipitor JA353 (DPP Orig. Am. Compl. ¶¶ 157-58). Nevertheless, as noted above, the PTO concluded that the patent application claimed nonobvious material and issued the ’995 Patent. The ’995 Patent expired on June 28, 2011. After obtaining the ’893 and ’995 Patents, Pfizer launched Lipitor in 1997. Following Lipitor’s 1997 launch, Pfizer obtained five additional patents, none of which, according to Lipitor plaintiffs, could delay further generic versions of the drug from coming to market. Pfizer listed all Lipitor patents in the FDA’s Orange Book, with the exception of certain “process” patents, which could not be listed. Lipitor plaintiffs allege fraud only as to the procurement and enforcement of the ’995 Patent. In August 2002, Ranbaxy obtained ANDA first-filer status for a generic version of Lipitor. Sometime later in 2002, Ranbaxy notified Pfizer of its paragraph IV certifications, which asserted that Ran-baxy’s sale, marketing, or use of generic Lipitor would not infringe any valid Pfizer patent. Pfizer subsequently sued Ranbaxy for patent infringement in the District of Delaware within the 45-day period prescribed by the Hatch-Waxman Act. Pfizer alleged that Ranbaxy’s generic would infringe the ’893 and ’995 Patents. As a result of Pfizer’s lawsuit, the FDA withheld approval of Ranbaxy’s ANDA for 30 months pursuant to the Hatch-Waxman Act. After a bench trial, the Delaware District Court ruled that Pfizer’s patents were valid and enforceable and would be infringed by Ranbaxy’s generic. Pfizer Inc. v. Ranbaxy Labs. Ltd., 405 F.Supp.2d 495, 525-26 (D. Del. 2005). In doing so, it rejected Ranbaxy’s argument that the ’995 Patent was procured by inequitable conduct. Id. at 520-25. On appeal, the Federal Circuit affirmed the District Court’s ruling that the ’893 Patent would be infringed. Pfizer Inc. v. Ranbaxy Labs. Ltd., 457 F.3d 1284, 1286 (Fed. Cir. 2006). But, the Federal Circuit reversed in part, holding that claim 6 of the ’995 Patent was invalid. Id. at 1291-92. On remand, the District Court enjoined FDA approval of Ran-baxy’s ANDA until March 24, 2010, the date of the ’893 Patent’s expiration. In July 2005, as the 30-month statutory window barring Ranbaxy’s generic market entry was closing, Pfizer filed a citizen petition with the FDA stating that the amorphous noncrystalline form of atorvas-tatin used in generic Lipitor (including in Ranbaxy’s, as identified in its ANDA) may be “inferior in quality” to branded Lipitor’s crystalline form. Lipitor JA1851. Lip-itor plaintiffs claim that this citizen petition was a sham. In particular, they allege that Pfizer’s citizen petition ignored both a decade-old FDA policy and FDA statements expressing the immateriality of drug form (i.e., crystalline versus amorphous), ignored Pfizer’s own use of the amorphous form of branded Lipitor in its clinical studies, and lacked any evidence to support its claims. In May 2006, the FDA informed Pfizer that it had not yet reached a decision on the petition, citing the need for further review and analysis given the “complex issues” it raised. Lipitor JA1877. The FDA eventually denied the citizen petition in a 12-page decision issued on November 30, 2011. In 2007, following the Federal Circuit’s ruling invalidating claim 6 of the ’995 Patent, Pfizer applied for a reissuance of the ’995 Patent to cure the relevant error. Ranbaxy filed an objection to the reissuance with the PTO. As explained below, however, Ranbaxy withdrew its objection, and the PTO reissued the ’995 Patent in April 2009, relying on Lipitor’s “commercial success,” without addressing whether Pfizer first obtained the patent using allegedly fraudulent submissions. During their Lipitor patent dispute, Pfizer and Ranbaxy also litigated a patent-infringement suit regarding a separate drug, Accupril. Pfizer owned the patent on Accupril, enjoying annual sales of over $500 million, Teva Pharmaceuticals first filed an ANDA seeking approval to market a generic version of Accupril. Ranbaxy subsequently filed an ANDA for Accupril as well. Pfizer sued Teva, resulting in Teva being enjoined from selling its generic until expiration of Pfizer’s Accupril patent. Meanwhile, Ranbaxy still sought to sell its version of generic Accupril but could not do so because of the 180-day exclusivity period (not yet triggered) available to Teva under the Hatch-Waxman Act. With Teva enjoined from selling its generic Accupril and Ranbaxy prevented from selling its generic, because of Teva’s first-filer exclusivity right, Teva and Ranbaxy entered into an agreement through which Teva became the .exclusive distributor of Ran-baxy’s generic. The parties agreed to split the profits from the sales, and Ranbaxy agreed to indemnify Teva for any liability related to the launch of its generic. Ran-baxy received approval for its generic version of Accupril in 2004. Shortly after receiving that approval, Ranbaxy launched its generic Accupril, and Pfizer brought suit almost immediately, seeking treble damages for willful infringement. Pfizer also sought a preliminary injunction against Ranbaxy and Teva, informing the court that Ranbaxy’s generic sales “decimated” its Accupril sales. The District Court in Pfizer’s Accupril action granted the injunction halting Ranbaxy’s generic sales, and the Federal Circuit affirmed the grant. Pfizer Inc. v. Teva Pharm. USA, Inc., 429 F.3d 1364, 1383 (Fed. Cir. 2005), Pfizer posted a $200 million bond in conjunction with the District Court’s entry of the injunction. After entry of the injunction, Pfizer expressed confidence that it would succeed in obtaining a substantial monetary judgment from Ran-baxy. On June 13, 2007, in light of the disputed Accupril patent’s expiration, the District Court vacated the preliminary injunction. The only issues that remained contested were Pfizer’s claims for past damages and Ranbaxy’s counterclaim as secured by the preliminary injunction bond. In March 2008, Pfizer again sued Ran-baxy in the District of Delaware over Lipitor; this time, Pfizer claimed that Ranbaxy’s generic Lipitor would infringe Pfizer’s two Lipitor-related process patents. Lipitor plaintiffs contend that this litigation was a sham because no imminent threat of harm to Pfizer existed and because Pfizer knew Ranbaxy’s generic would not violate those patents. They assert that the actual purpose of Pfizer’s suit was to create “the illusion of litigation” so that the parties could enter a settlement agreement. Lipitor JA254 (DPP Sec. Am. Compl. ¶ 137). , Not long after Pfizer brought suit against Ranbaxy, on June 17, 2008, Pfizer and Ranbaxy executed a near-global litigation settlement — which Lipitor plaintiffs allege constituted an unlawful reverse payment — regarding scores of patent liti-gations around the world, including the Lipitor and Accupril disputes. The settlement ended the Accupril litigation with prejudice, and brought to a close not only all domestic patent infringement litigation between Pfizer and Ranbaxy pertaining to Lipitor, but also all foreign litigation between the two companies over Lipitor. By the settlement’s terms, Ranbaxy agreed to delay its entry in the generic Lipitor market until November 30, 2011. In addition, Pfizer and Ranbaxy negotiated similar market entry dates for generic Lipitor in several foreign jurisdictions. Ranbaxy also paid $1 million to Pfizer in connection with the Accupril litigation, and Pfizer’s $200 million injunction bond from the Accupril litigation was released. Ranbaxy further agreed to cease its protests.on the ’995 Patent’s reissuance. (As noted above, the PTO subsequently issued the ’995 Patent in March 2009.) Although not alleged .in their complaints, the settlement also created a Canadian supply arrangement for generic Lipitor between the parties and resolved other litigation regarding the pharmaceutical drug Caduet. Ranbaxy delayed generic entry until November 2011, thus extending Pfizer’s exclusivity in the Lipitor market twenty months beyond the expiration of the ’893 Patent and five months beyond the expiration of what Ranbaxy alleged was the fraudulently procured ’995 Patent. As a result, Ranbaxy’s delayed entry created a bottleneck in the entry of generic Lipitor from later ANDA filers. Due to its ANDA first-filer status, Ranbaxy was entitled to the first-filer 180-day generic market exclusivity. Under the settlement agreement, though, Ranbaxy would not trigger that period by entering the generic market until November 2011. That meant that any other would-be generic manufacturer that wanted Ranbaxy’s 180-day period to begin earlier than November 2011 needed a court to hold that all of Pfizer’s Lipitor patents listed in the Orange Book were invalid or not infringed. Pfizer helped to forestall this possibility, Lipitor plaintiffs assert, through a combination of lawsuits against subsequent ANDA filers. The FDA ultimately approved Ranbaxy’s Lipitor ANDA on November 30, 2011, the day Ranbaxy’s license to the unexpired Lipitor patents with Pfizer commenced. 2 Beginning in late 2011, Lipitor direct purchasers and end payors filed separate antitrust1 actions in various federal district courts. The cases were subsequently referred to the Judicial Panel on Multidis-trict Litigation (“JPML”) for coordination. The JPML transferred each case to the District of New Jersey, assigning the matters to District Judge Peter G. Sheridan. See In re Lipitor Antitrust Litig., 856 F.Supp.2d 1355 (J.P.M.L. 2012). Thereafter,- the direct-purchaser and end-payor plaintiffs filed amended class action complaints; Lipitor individual-retailer plaintiffs likewise filed complaints joining the consolidated proceedings. The complaints raise two substantively identical claims: (1) a- monopolization claim under Section 2 of the Sherman Act (15 U.S.C. § 2) or a state analogue against Pfizer, asserting that the company engaged in an overarching anticompetitive scheme that involved fraudulently procuring the ’995 Patent from the PTO (Walker Process fraud), falsely listing that patent in' the FDA’s Orange Book, enforcing the ’995 Patent and certain process patents through sham litigation, filing a sham citizen petition with the FDA, and entering into a reverse payment settlement agreement with Ranbaxy; and (2) a claim under Section 1 of the Sherman Act (15 U.S.C. § 1) or a state analogue against both Pfizer and Ranbaxy, challenging the settlement agreement as an unlawful restraint of trade. Lipitor defendants filed motions to dismiss all the complaints under Rule 12(b)(6) of the Federal Rules of Civil Procedure. During the pendency of those motions, on May 16, 2013, the District Court stayed proceedings, awaiting the Supreme Court’s decision in Actavis. Following that decision on June 17, 2013, the District Court reopened the case and permitted the parties to file supplemental briefs on the pending motions to dismiss. On September 5, 2013, the District Court dismissed Lipitor plaintiffs’ complaints to the extent they were based on anything other than the reverse payment settlement agreement. In re Lipitor Antitrust Litig., 2013 WL 4780496, at *27 (D.N.J. Sept. 5, 2013) (Lipitor I). The Court specifically rejected the Walker Process fraud, false Orange Book listing, sham litigation, sham FDA citizen petition, and overall monopolistic scheme allegations related to Lipitor plaintiffs’ monopolization claims against Pfizer. Id. at *15-23. However, the Court granted leave 'to file amended complaints focused solely on the reverse payment settlement agreement between Pfizer and Ranbaxy. Id. at *25-27. Lipitor plaintiffs filed amended complaints in October 2013. The direct purchasers and end payors attached their pri- or complaints as exhibits to their new complaints to preserve the allegations that had been dismissed for appeal. Similarly, the independent retailers stated in the first paragraph of their new complaints that they were also preserving the previously dismissed allegations. In November 2013, Lipitor defendants moved to dismiss the amended complaints. On September 12, 2014, the District Court dismissed the direct purchaser’s amended complaint with prejudice, rejecting the remaining allegations relating to the reverse payment settlement agreement between Pfizer and Ranbaxy. In re Lipitor Antitrust Litig., 46 F.Supp.3d 523 (D.N.J. 2014) (Lipitor II). The complaints of the end payor and individual retailers were dismissed that same day in light of the District Court’s dismissal of the direct purchasers’ complaint. On October 10, 2014, the direct purchasers filed a motion to amend the judgment and for leave to file an amended complaint, contending that the District Court applied “a new, heightened pleading standard.” Lipitor JA151. That motion was denied on March 16, 2015. These timely appeals followed. B In In re Effexor XR Antitrust Litigation, Nos. 15-1184 et al., plaintiffs are a putative class of direct purchasers of branded Effexor XR, a putative class of end payors, two individual third-party pay-ors, and several individual retailers asserting direct-purchaser claims. We will refer to these parties collectively as the “Effexor plaintiffs.” Defendants are Wyeth, Inc., Teva Pharmaceutical Industries Ltd., and their respective corporate affiliates. We will likewise refer to these parties collectively as the “Effexor defendants.” As with the Lipitor appeals, we proceed by outlining the factual background behind these consolidated appeals and then describing their procedural history. 1 Effexor is a brand-name drug used to treat depression. In 1985, the PTO issued American Home Products, Wyeth’s predecessor, a patent for Effexor’s active ingredient — the compound venlafaxine hydrochloride. The patent for that compound expired on June 13, 2008. In 1993, the FDA granted Wyeth approval to begin marketing Effexor, which Wyeth did with respect to an instant-release version of the drug (or “Effexor IR”). Four years later, the FDA granted Wyeth approval for Effexor XR, an extended-release, once-daily version of the drug. Wyeth obtained three patents for Effexor XR, all of which expired on March 20, 2017. Effexor plaintiffs contend that Wyeth obtained the Effexor XR patents through fraud on the PTO, improperly listed those patents in the FDA’s Orange Book, and enforced those patents through serial sham litigation. On December 10, 2002, Teva obtained ANDA first-filer status for a generic version of Effexor XR. Teva’s ANDA included paragraph IV certifications, asserting that Teva’s sale, marketing, or use of generic Effexor would not infringe Wyeth’s patents or that those patents were invalid or unenforceable. As the first company to file an ANDA with a paragraph IV certification for generic Effexor XR, Teva was entitled to the Hatch-Waxman Act’s 180-day period of marketing exclusivity. Within the 45-day period prescribed by the Hatch-Waxman Act, Wyeth brought suit against Teva for patent infringement in the District of New Jersey. In October 2005, shortly after the District Court held a Markman hearing on patent claim construction, Wyeth and Teva reached a settlement. Effexor plaintiffs allege that the District Court’s ruling at the Markman hearing spurred the parties to reach a settlement agreement, as Wyeth feared that it would lose the litigation. A loss would have enabled other generic manufacturers to then enter the Effexor XR market. Under the terms of the settlement, Wyeth and Teva agreed to vacate the Markman ruling. They further agreed to a market entry date of July 1, 2010, for Teva’s generic Effexor XR, nearly seven years before the expiration of Wyeth’s patents. Wyeth further agreed that it would not market an authorized-generic Effexor XR during Teva’s 180-day exclusivity period (the “no-AG agreement”). Effexor plaintiffs allege that Wyeth’s promise to stay out of the generic Effexor XR market was worth more than $500 million, observing that Teva would gain all the sales of generic Effexor XR during Teva’s generic exclusivity period. Wyeth also agreed to allow Teva to sell a generic version of Wyeth’s Effexor IR before the original patent for Effexor expired in June 2008, and Wyeth promised not to launch an authorized generic to compete with Teva’s instant-release generic. In return, and in addition to the delayed entry date for generic Effexor XR, Teva agreed to pay royalties to Wyeth. With regard to its generic Effexor XR sales, Teva would pay Wyeth royalties beginning at 15% during its 180-day exclusivity period. If Wyeth chose not to introduce an authorized generic after 180 days and no other generic entered the market, Teva was required to pay Wyeth 50% royalties for the next 180 days and 65% royalties thereafter for up to 80 months. As to Teva’s sales of generic Effexor IR, Teva agreed to pay Wyeth 28% royalties during the first year and 20% during the second year. In November 2005, Wyeth and Teva filed the settlement agreement with the District Court presiding over the patent-infringement litigation. As required by a 2002 consent decree, Wyeth submitted the agreement to the Federal Trade Commission (“FTC”), which possessed the right to weigh in on and raise objections to Wyeth’s settlements. The FTC offered no objection but reserved its right to take later action. The settlement was also submitted to the U.S. Department of Justice, and again to the FTC, pursuant to Section 1112 of the Medicare Prescription Drug, Improvement, and Modernization Act of 2003 (“MMA”), Pub. L. No. 108-173, 117 Stat. 2066, 2461-63 (2003) (codified at 21 U.S.C. § 355 note). The District Court thereafter entered orders vacating its pri- or Markman rulings, dismissing the case, and -adopting in summary fashion the terms of the settlement as a consent de--cree and permanent injunction. Effexor JA1298. Following the Wyeth-Teva settlement, between April 2006 and April 2011, Wyeth brought patent-infringement suits against sixteen other companies that sought to market a generic version of Effexor XR. Each lawsuit ended in settlement and without a-court order regarding the validity or enforceability of Wyeth’s patents. 2 Beginning in May 2011, several direct purchasers of Effexor XR filed class action complaints raising various antitrust claims in the U.S. District Court for the Southern District of Mississippi. Those cases were consolidated and, on September 21, 2011, that Court transferred the action to District Judge Peter G. Sheridan in the U.S. District Court for- District of New Jersey. After the consolidation and transfer, the direct purchasers filed an amended consolidated class action complaint, a group of end payors joined the case with a consolidated class action complaint, several individual retailers filed complaints, and two individual third-party payors together filed their own complaint. As with the consolidated Lipitor appeals, their complaints each raise two substantively identical claims: (1) a monopolization claim under Section 2 of the Sherman Act (15 U.S.C, § 2) or a state analogue against Wyeth, asserting that Wyeth fraudulently induced the PTO to issue the three patents covering. Effexor XR (Walker Process fraud), improperly listed those patents in the Orange Book, enforced those patents through serial sham litigation, and entered into a reverse payment settlement with Teva; and (2) a .claim under Section 1 of the Sherman Act (16 U.S.C. § 1) or a state analogue - against both Wyeth and Teva, alleging the reverse payment settlement agreement between them was an unlawful restraint of trade. • In April 2012, Effexor defendants filed motions to dismiss under Rule 12(b)(6). During the pendency of those motions, the District Court stayed proceedings in October 2012 pending the Supreme Court’s decision in Actavis. Following the Actavis ruling, the District Court vacated the stay, reopened the case, and called for supplemental briefing on the pending motions to dismiss. On' October 23, 2013, the direct purchasers' (but no other party) filed an amended complaint. That amended complaint was met with a renewed motion to dismiss. On October 6, 2014, the District Court granted in part and denied in part Effexor defendants’ motions to dismiss. In re Effexor XR Antitrust Litig., No. CIV.A. 11-5479 PGS, 2014 WL 4988410 (D.N.J. Oct. 6, 2014). It granted the motions to dismiss, with prejudice, as to Effexor plaintiffs’ challenges to the reverse payment settlement agreement between Wyeth and Teva under Section 1 of the Sherman Act (or its state analogue). Id. at *19-24. The District Court denied the motions as they related to the remaining allegations of Effexor plaintiffs against Wyeth. Id. at *24-26. At Effexor plaintiffs’ request, the District Court directed entry of a final judgment as to the Section 1 claims (or their state analogues) against Wyeth and Teva under Rule 54(b) of the Federal Rules of Civil Procedure. These timely appeals followed. III The District Court had subject-matter jurisdiction with respect to the Lipitor and Effexor direct purchasers and independent retailers under 28 U.S.C. §§ 1331 and 1337(a), the Lipitor and Effexor end pay-ors under 28 U.S.C. § 1332(d), and the Effexor independent third-party payors under 28 U.S.C. § 1332(a)(3). We have appellate jurisdiction pursuant to 28 U.S.C. § 1291. In April 2017, this Court concluded that the Lipitor and Effe-xor consolidated actions did not “arise under” patent-law and consequently denied Lipitor and Effexor plaintiffs’ request for a transfer to the U.S. Court of Appeals for the Federal Circuit. In re Lipitor Antitrust Litig., 855 F.3d at 145-46; see also 28. U.S.C. § 1338(a) (providing district courts with original jurisdiction over actions “arising under” federal, patent law); 28 U.S.C. § 1295(a) (providing the U.S. Court of Appeals for the Federal Circuit with “exclusive jurisdiction” over “an appeal from a final decision ... in any civil action arising under” federal patent law). Appellate jurisdiction, therefore, is proper in this Court, not the Federal Circuit. We review dismissals under Rule 12(b)(6) of the Federal Rules of Civil Procedure de novo. See Phillips v. County of Allegheny, 515 F.3d 224, 230 (3d Cir. 2008). We accept all factual allegations in the complaint as true and, examining for plausibility, “determine whether, under any reasonable reading of the complaint, the plaintiff may be entitled to relief.” Bronowicz v. Allegheny County, 804 F.3d 338, 344 (3d Cir. 2015) (quoting Powell v. Weiss, 757 F.3d 338, 341 (3d Cir. 2014)). As part of that review, we may consider documents “integral to or explicitly referred to in the complaint” without turning a motion to dismiss into a motion for summary judgment. Schmidt v. Skolas, 770 F.3d 241, 249 (3d Cir. 2014) (quoting In re Burlington Coat Factory Sec. Litig., 114 F.3d 1410, 1426 (3d Cir. 1997)). With allegations of fraud, “a party must state with particularity the circumstances constituting fraud or mistake,” although “intent, knowledge, and other conditions of a person’s mind may be alleged generally.” Fed. R. Civ. P. 9(b); see also U.S. ex rel. Moore & Co., P.A. v. Majestic Blue Fisheries, LLC, 812 F.3d 294, 307 (3d Cir. 2016) (“A plaintiff alleging fraud must therefore support its allegations ‘with all of the essential factual background that would accompany the first paragraph of any newspaper story — that is, the who, what, when, where and how of the events at issue.’ ” (quoting In re Rockefeller Ctr. Props., Inc. Securities Litig., 311 F.3d 198, 217 (3d Cir. 2002))); In re DDAVP Direct Purchaser Antitrust Litig., 585 F.3d 677, 695 (2d Cir. 2009) (requiring that allegations of fraudulent procurement of a patent be pled with particularity). In doing so, “a party must plead [its] claim with enough particularity to place defendants on notice of the ‘precise' misconduct with which they are charged.’” United States ex rel. Petras v. Simparel, Inc., 857 F.3d 497, 502 (3d Cir. 2017) (quoting Lum v. Bank of Am., 361 F.3d 217, 223-24 (3d Cir. 2004), abrogated on other grounds by Bell Atl. Corp. v. Twombly, 550 U.S. 544, 557, 127 S.Ct. 1955, 167 L.Ed.2d 929 (2007)). IV In F.T.C. v. Actavis, the Supreme Coqrt held that reverse payments made pursuant to settlement agreements (“reverse payment settlement agreements”) may give rise to antitrust liability. 133 S.Ct. at 2227. Often arising from pharmaceutical drug litigation, reverse payment settlement agreements operate counter to conventional settlement norms. As traditionally understood,, settlements , involve an agreement by a defendant (i.e., a patent infringer in the pharmaceutical drug context) to pay a plaintiff (i.e., the patentee) to end a lawsuit. A reverse payment settlement agreement instead “requires the patentee to pay the alleged infringer,” in return for the infringer’s agreement not to produce the patented item. Id. To make that abstract explanation more concrete, the Supreme Court gave the following unadorned example: “Company A sues Company B for patent infringement. The two companies settle under terms that require (1) Company B, the claimed infringer, not to produce the patented product until the patent’s term expires, and (2) Company A, the patentee, to pay B many millions of dollars.” Id, Prior to Actavis, several courts had held that such settlement agreements “were immune from antitrust scrutiny so long as the asserted anticompetitive effects fell within the scope of the patent.” King Drug Co., 791 F.3d at 399. That categorical rule, known as the “scope of the patent” test, relied on the premise that, because a pat-entee possesses a lawful right to keep others out of its market, the patentee may also enter into settlement agreements excluding potential patent challengers from entering that market. Actavis, 133 S.Ct. at 2230. The Supreme Court rejected that approach. Its main concern was the use of reverse payments “to avoid the risk of patent invalidation or a finding of nonin-fringement.” Id. at 2236. It reasoned that “to refer ... simply to what the holder of a valid patent could do does not by itself answer the antitrust question. The patent ... may or may not be valid, and may or may not be infringed.” Id. at 2230-31. Therefore, “determining] antitrust legality by measuring the settlement’s anticompeti-tive effects solely against patent law policy, rather than by measuring them against procompetitive antitrust policies as well,” would be “incongruous.” Id. at 2231. Instead, “patent and antitrust policies are both relevant in determining the ‘scope of the patent monopoly5 — and consequently antitrust law immunity — that is conferred by a patent.” Id. Hence, patent-related “reverse payment settlements ... can sometimes violate the- antitrust laws[.]” King Drug Co., 791 F.3d at 399 (first alteration in original) (quoting Actavis, 133 S.Ct. at 2227). In determining that reverse payment settlement agreements may violate antitrust laws, the Supreme Court offered limited guidance as to when such settlements should be subject to antitrust scrütiny. It exempted “commonplace forms” of settlement from scrutiny. Actavis, 133 S.Ct. at 2233. One such settlement is a payment where “a party with a claim (or counterclaim) for damages receives a sum equal to or less than the value of its claim.” Id. at 2233 (“[W]hen Company A sues Company B for patent infringement and demands, say, $100 million in damages, it is not uncommon for B (the defendant) to pay A (the plaintiff) some amount less than the full demand as part of the settlement — $40 million, for example.”). Another such settlement is a payment by a plaintiff (i.e., the patent holder) settling a counterclaim made by a defendant (i.e., the alleged patent infringer). Id. (“[I]f B has a counterclaim for. damages against A, the original infringement plaintiff, A might end up paying B to settle B’s counterclaim.”). In contrast to those commonplace forms of settlement, a reverse payment in pharmaceutical drug litigation occurs when “a party with no' claim for damages (something that is usually true of a paragraph IV litigation defendant) walks away'with money simply so it will stay away from the patentee’s market.” Id. At base, reverse payments violate antitrust law when they unjustifiably seek “to prevent the risk of competition.” Id. at 2236. “If the basic reason [for the payment] is a desire to maintain and to share patent-generated monopoly profits, then, in the absence of some other justification, the antitrust laws are likely to forbid the arrangement.” Id. at 2237; see also id. at 2236 (“[T]he payment (if otherwise unexplained) likely seeks to prevent the risk of competition. And, as we have said, that consequence constitutes the relevant anticompetitive harm.”). Stated differently, a reverse payment may demonstrate “that the patentee seeks to induce the ... challenger to abandon its claim with a share of its monopoly profits that would otherwise be lost in the competitive market.” Id. at 2235. Reverse payment settlement agreements give rise to those antitrust concerns — that is, the concern that a settlement seeks “to eliminate risk of patent invalidity or noninfringement,” King Drug Co., 791 F.3d at 411—when the payments are both “large and unjustified.” Actavis, 133 S.Ct. at 2237. Consideration of the size of the reverse payment serves at least two functions in assessing that payment’s lawfulness. First, the Supreme Court observed .that a large reverse payment may indicate that “the patentee likely possesses the power to bring [an unjustified anticompetitive] harm about in practice.” Id. at 2236; see also King Drug Co., 791 F.3d at 403 (“[T]he size of a reverse payment may serve as a proxy for [the power to bring about anti-competitive harm] because a firm without such power (and the supracompetitive profits that power enables) is unlikely to buy off potential competitors.”). That is, a large reverse payment may signal that the patentee possessed “the power to charge prices higher than the competitive level” and may be using that power to keep others from entering its market. Actavis, 133 S.Ct. at 2236. Second, a large reverse payment may signify that- the payment seeks to avoid invalidation of the disputed underlying patent. Id. at 2236. A patent holder may be concerned about the validity of its patent, and so the size of the payment may very well correspond with the magnitude of that concern. See id. at 2236-37 (“In a word, the size of the unexplained reverse payment can provide a workable surrogate for a patent’s weakness.... ”). The justifications underlying the reverse payment also play a role in determining whether that payment will give rise to antitrust liability. The Supreme Court observed, on the one hand, that “[w]here a reverse payment reflects traditional settlement considerations, ... there is not the same concern [as with other reverse payments] that a patentee is using its monopoly profits to avoid the risk of patent invalidation or a finding of noninfringement.” Id. at 2236. Those legitimate justifications for a reverse payment include those where the payment is “a rough approximation of the litigation expenses saved through settlement” or a reflection of “compensation for other services the generic has promised to perform.” Id. The Supreme Court did not exclude other possible legitimate explanations from also justifying reverse payment settlement agreements. Id. On the other hand, in the absence of a legitimate justification or explanation, the reverse payment “likely seeks to prevent the risk of competition” in that its “objective is to maintain supracompetitive prices to be shared among the patentee and the challenger rather than face what might have been a competitive market.” Id. “In sum, a reverse payment, where large and unjustified, can bring with it the risk of significant anticompetitive effects .... ” Id. at 2237. Therefore, to survive a motion to dismiss when raising an antitrust violation under Actavis, “plaintiffs must allege facts sufficient to support the legal conclusion that the settlement at issue involves a large and unjustified re-veíase payment under Actavis.” In re Loestrin 24 Fe Antitrust Litig., 814 F.3d 538, 552 (1st Cir. 2016). If plaintiffs do so, they may proceed to prove their allegations under the traditional antitrust rule-of-reason analysis. See Actavis, 133 S.Ct. at 2237. Since Actavis, this Court has had occasion to assess the plausibility of allegations raising an unlawful reverse payment settlement agreement. In King Drug Co. of Florence, Inc. v. SmithKline Beecham Corp., we reached two conclusions relevant here regarding the parameters of antitrust claims brought under Actavis. First, we held that a reverse payment underlying an Actavis antitrust claim need not be in cash form. 791 F.3d at 403-09. The allegedly unlawful reverse payment took the form of a' “no-AG agreement,” a brand-name manufacturer’s promise not to produce an authorized generic to compete with the generic manufacturer. Id. at 397. There, the direct purchasers of a drug (Lamictal) sued both GlaxoSmithKline (GSK), the bránd-name manufacturer, and Teva, the generic manufacturer, for violating Sections 1 and 2 of the Sherman Act. Id. at 393. The direct purchasers alleged that GSK and Teva entered into an agreement settling GSK’s patent infringement suit, which contained a no-AG agreement. Id. at 397. The no-AG agreement provided that GSK would not produce an authorized generic version of Lamictal for 180 days after Teva started marketing its generic. Id. The King Drug Co. plaintiffs argued that the no-AG agreement could constitute an anticompetitive reverse payment under Actavis because it worked to maintain su-pracompetitive prices in the Lamictal market. Id. at 397, 410. We agreed, holding “that a no-AG agreement, when it represents an unexplained large transfer of value from the patent holder to the alleged infringer, may be subject to .antitrust scrutiny under the rule of reason.” Id. at 403. We also determined that the plaintiffs in King Drug 'Co. plausibly alleged that the no-AG agreement was a large and unjustified reverse payment sufficient to support antitrust scrutiny under Actavis. Id. at 409-10. The allegations 'giving rise to antitrust review were that (1) “GSK agreed not to launch a competing authorized generic during Teva’s 180-day exclusivity period”; (2) “GSK had an incentive to launch its own authorized generic versions of tablets”; (3) GSK’s promise could be “worth many millions of dollars of additional revenue”; (4) “Teva had a history of launching ‘at, risk’ ”; and (4) the relevant “patent was likely to be invalidated.” Id. Given those allegations, we reasoned that the complaint plausibly alleged that the reverse payment was large and unjustified and attempted to prevent the risk of competition through the sharing of monopoly profits: “Because marketing an authorized generic was allegedly in GSK’s economic interest, its agreement not to launch an authorized generic was ah inducement — valuable to both it and Teva — to ensure a longer period of supracompetitive monopoly profits based on a patent at risk of being found invalid or not infringed.” Id. at 410. In reaching that conclusion, we specifically rejected GSK and Teva’s argument that the reverse payment was justified because Teva was given permission in the settlement agreement to enter a different pharmaceutical, drug market early. We observed that, according to the complaint, the early-entry provision allowed access to a market worth “only $50 million annually,” which “was orders of magnitude smaller than the alleged $2 billion ... market the agreement is said to have protected.” Id. The early-entry provision thus failed to justify the large reverse payment from the patentee GSK to the alleged in-fringer Teva. Id. Because the complaint in King Drug Co. plausibly alleged a large and unjustified reverse payment, the plaintiffs there could proceed to prove their claim through “the traditional rule-of-reason approach.” Id. at 411; see also id. at 412 (providing a three-step rule-of-reason approach by which antitrust plaintiffs could demonstrate that the reverse payment settlement agreement imposed an unreasonable restraint on competition). Applying Adorns and King Drug Co., we next address whether the complaints in the Lipitor and Effexor consolidated appeals plausibly allege an actionable reverse payment settlement agreement. A We conclude that Lipitor plaintiffs have plausibly pled an unlawful reverse payment settlement agreement. Their allegations sufficiently allege that Pfizer agreed to release the Aceupril claims against Ranbaxy, which were likely to succeed and worth hundreds of millions of dollars, in exchange for Ranbaxy’s delay in the release of its generic version of Lipitor. As part of their effort to allege an unlawful reverse payment settlement agreement, Lipitor plaintiffs plead, among other factual averments, the following: Ranbaxy launched a generic version of Pfizer’s brand drug Aceupril “at risk,” Lipitor JA257 (DPP Sec. Am. Compl. ¶ 149); Pfizer had annual Aceupril sales over $500 million prior to Ranbaxy’s launch, id.-, Pfizer brought suit and sought to enjoin Ran-baxy’s generic sales, Lipitor JA260 (DPP Sec. Am. Compl. ¶ 160); the District Court granted the injunction halting Ranbaxy’s sales of generic Aceupril, which the Federal Circuit affirmed, Pfizer Inc. v. Teva Pharm. USA, Inc., 429 F.3d 1364, 1383 (Fed. Cir. 2005); Pfizer posted “a $200 million bond in conjunction with” the injunction and informed the Court that Ran-baxy’s generic sales “decimated” its Accu-pril sales, Lipitor JA260 (DPP Sec. Am. Compl. ¶ 160); more specifically, Pfizer’s Aceupril sales dropped from $525 million in 2004 to $71 million in 2005 following Ranbaxy’s launch of the generic version of Aceupril, Lipitor JA260 (DPP Sec. Am. Compl. ¶ 160); Pfizer’s suit was likely to be successful, Lipitor JA262-63 (DPP Sec. Am. Compl. ¶¶ 167-70); and Pfizer itself made statements about Ranbaxy’s exposure, estimating that Ranbaxy faced “very, very substantial damages in the way of lost profits,” Lipitor JA263 (DPP Sec. Am. Compl. ¶ 170). Despite the large expected damages arising from the Aceupril suit and the high likelihood of its success, Pfizer subsequently released its Aceupril claims as part of a settlement agreement with Ranbaxy. Ran-baxy paid $1 million to Pfizer in connection with the Aceupril litigation and also agreed to the release of Pfizer’s $200 million injunction bond. Lipitor plaintiffs allege that the release of the Aceupril claims was unjustified, as the release of potential liability in Aceupril “far exceeded” any of Pfizer’s saved litigation costs or any services provided by Ranbaxy. Lipitor JA265 (DPP Sec. Am. Compl. ¶¶ 180, 285). Pfizer’s alleged,agreement to release the Ac-cupril claims, therefore, “was an inducement — valuable to both it and [Ranbaxy]— to ensure a longer period of supracompeti-tive monopoly profits based on [the Lipitor patent, which was] at risk of being found invalid or not infringed.” King Drug Co., 791 F.3d at 410. Those allegations sufficiently plead that the value of the Accupril claims was large and their release was unjustified. See Actavis, 133 S.Ct. at 2236 (“[T]he payment (if otherwise unexplained) likely seeks to prevent the risk of competition .... [T]hat consequence constitutes the relevant anticompetitive harm.”). Notwithstanding Lipitor plaintiffs’ allegations, the District Court determined their complaints were wanting. It required that they plead a “reliable” monetary estimate of the dropped Accupril claims so that they “may be analyzed against the Actavis factors” to determine whether the value of those claims “is ‘large’ once the subtraction of legal fees and other services provided by generics occurs.” See Lipitor II, 46 F.Supp.3d at 543. That “reliable” monetary estimate, according to the Court, necessitated a series of calculations: a valuation of Pfizer’s damages in the Accupril litigation incorporating both Pfizer’s probability of success in that action and an estimation of Pfizer’s lost profits; a discounting of Pfizer’s damages based on its saved litigation costs and Pfizer’s various litigation risks; and an accounting of various other provisions within the settlement agreement, including the arrangement to allow Ranbaxy into several foreign markets, the parties’ agreement resolving other pharmaceutical litigation, and a supply arrangement between Ranbaxy and Pfizer related to generic Lipitor sales in Canada. Without these various calculations, the District Court determined that Lipitor plaintiffs had failed to allege a plausible large and unjustified reverse payment under Actavis. Lipitor defendants largely echo the reasoning of the District Court. Their contentions broadly fall into two categories. First, and similar to the District Court, Lipitor defendants maintain that, even if the settlement could be characterized as an unlawful reverse payment, Lipitor plaintiffs insufficiently alleged the payment was “large” and “unjustified.” Second, they argue that the settlement here was no more than the sort of commonplace settlement that the Supreme Court excluded from antitrust scrutiny. Neither of these arguments withstands careful review. Both the District Court and Lipitor defendants offer a heightened pleading standard contrary to Bell Atlantic Corp. v. Twombly, 550 U.S. 544, 127 S.Ct. 1955, 167 L.Ed.2d 929 (2007), and Ashcroft v. Iqbal, 556 U.S. 662, 129 S.Ct. 1937, 173 L.Ed.2d 868 (2009). Twombly and Iqbal require only plausibility, a standard “not akin to a ‘probability requirement.’ ” Iqbal, 556 U.S. at 678, 129 S.Ct. 1937. While Twombly and Iqbal require that “[fjactual allegations ... be enough to raise a right to relief above the speculative level,” Twombly, 550 U.S. at 555, 127 S.Ct. 1955, “those cases make it clear that a claimant does not have to ‘set out in detail the facts upon which he bases his claim.’ ” Covington v. Int’l Ass’n of Approved Basketball Officials, 710 F.3d 114, 118 (3d Cir. 2013) (quoting Twombly, 550 U.S. at 555 n.3, 127 S.Ct. 1955); see also Connelly v. Lane Const. Corp., 809 F.3d 780, 786 (3d Cir. 2016) (“[Djetailed pleading is not generally required.”). Applying that pleading standard, neither the Supreme Court in Actavis nor this Court in King Drug Co. demanded the level of detail the District Court and Lipitor defendants would require. For its part, the Supreme Court in Actavis was deliberately opaque about the parameters of reverse payment antitrust claims. We take note, though, of the allegations in Actavis regarding the size of the reverse payment. There, the FTC alleged simply that a pat-entee “agreed to pay [a generic manufacturer] $10 million per year for six years,” “agreed to pay [another generic manufacturer] $2 million per year for six years,” and “projected that it would pay [a third generic manufacturer] about $19 million during the first year of its agreement, rising to over $30 million annually by the end of the deal.” Second Amended Complaint for Injunctive and Other Equitable Relief ¶¶ 66, 77, In re Androgel Antitrust Litig., No. 1:09-CV-00955-TWT (N.D. Ga. May 28, 2009), ECF No. 134. The FTC’s complaint did not preemptively negate justifications for the reverse payments. It simply alleged that the payments were meant to, and did, induce delay of likely successful patent challenges through the sharing of monopoly profits. Id. ¶¶ 67, 86; see also Actavis, 133 S.Ct. at 2229. The Supreme Court did not require the advanced valuations asked for by Lipitor defendants and required by the District Court. Perhaps equally striking in their simplicity are the allegations we concluded were sufficient to state an Actavis claim in King Drug Co. There, we elucidated no special valuation requirement in examining the alleged reverse payment. Rather, the allegations were simply that a no-AG agreement provided the alleged infringer with “many millions of dollars of additional revenue” and that the patentee otherwise had “an incentive to launch its own authorized generic.” King Drug Co., 791 F.3d at 409-10. The no-AG agreement resultantly induced the alleged infringer to agree to delay the launch of its generic drug that would compete with the patentee’s drug, which purportedly relied on an invalid patent. Id. Nothing more was necessary to plausibly plead a claim under Actavis. The allegations here, as outlined above, easily match, if not exceed, the level of specificity and detail of those in Actavis and King Drug Co. The alleged reverse payment here was “large” enough to permit a plausible inference that Pfizer possessed the power to bring about an unjustified anticompetitive harm through its patents and had serious doubts about the ability of those patents to lawfully prevent competition. Actavis, 133 S.Ct. at 2236. Pfizer purportedly suffered hundreds of millions of dollars in lost sales following Ranbaxy’s entry into the Accupril market. Lipitor JA260 (DPP Sec. Am. Compl. ¶ 160). Upon suing Ranbaxy, Pfizer sought treble damages, Lipitor JA263-64 (DPP Sec. Am. Compl. ¶¶ 159,172-74), and posted a $200 million bond to secure an injunction, “demonstrating that Pfizer placed great value on preserving its Accu-pril franchise,” Lipitor JA260 (DPP Sec. Am. Compl. ¶ 160). That claim had some likelihood of success given the entry of the injunction, which was affirmed on appeal. See Pfizer, 429 F.3d at 1383. Pfizer itself told shareholders that it was likely to succeed on the merits of the case. Lipitor JA263 (DPP Sec. Am. Compl. ¶ 170). Despite those losses and the likely success of that litigation against Ranbaxy, Pfizer released its claim worth “hundreds of millions of dollars.” JA264 (DPP Sec. Am. Compl. ¶ 175). Those allegations sufficiently allege a large reverse payment; more detailed, advanced calculations related to those allegations may come later. The alleged reverse payment here was also “unjustified.” As noted earlier, avoiding litigation costs, providing payment for services, or other consideration may justify a large reverse payment. See Actavis, 133 S.Ct. at 2236. To plausibly allege an unjustified reverse payment, an antitrust plaintiff need only allege the absence of a “convincing justification” for the payment. Id. at 2236-37 (observing that, if such considerations are present, “there is not the same concern that a patentee is using its monopoly profits to avoid the risk of patent invalidation or a finding of noninfringement”); see also King Drug Co., 791 F.3d at 412 (observing that, in the first step of the rule-of-reason analysis, a plaintiff must “prove a payment for delay, or, in other words, payment to prevent the risk of competition,” and then citing Actavis for the proposition that the “likelihood of a reverse payment bringing about anticom-petitive effects” depends on its size, anticipated litigation costs, its independence from other services rendered, and other justifications). Lipitor plaintiffs’ complaints state that the value of the released Accupril claims “far exceed[s] any litigation costs (in any or all cases) Pfizer avoided by settling.” Lipitor JA265 (DPP Sec. Am. Compl. ¶ 180). While Lipitor defendants speculate as to the actual saved litigation costs, all that need be alleged, at this juncture, is that those costs fail to explain the hundreds of millions of dollars of liability released by Pfizer. Lipitor plaintiffs have alleged just that, and the finely calibrated litigation cost estimates requested by Lipitor defendants and the District Court are unnecessary at this stage in the litigation. Lipitor defendants also argue that the alleged reverse payment was pled out of context, as the Accupril litigation settlement was part of a larger, global settlement agreement between Pfizer and Ran-baxy. Specifically, they point out that the complaints do not address other aspects of the settlement agreement, namely a supply arrangement in Canada and resolution of litigation over another pharmaceutical drug, Caduet. They are correct that the complaints make little mention of those aspects of the settlement. We disagree that the absence of those allegations is fatal. .... Lipitor defendants have the burden of justifying the rather large reverse payment here, and they offer no reason why tho