Letter to the FTC About the Clustering of the Pricing of GLP 1 Agonists

Office of Policy and Coordination Bureau of Competition Federal Trade Commission 600 Pennsylvania Avenue, NW Washington, DC 20580 RE: Clustering of High Prices of GLP 1 Agonists in the USA, Compared to other First World Nations. Dear Madam or Sir: GLP-1 agonists, also known as incretin mimetics, mimic the effects of a hormone called glucagon-like peptide-1 (GLP-1). GLP-1 is produced in the gut and helps regulate blood sugar levels by stimulating insulin release and reducing glucagon production. They can: 1) Improve blood sugar control: By mimicking GLP-1, these drugs help the pancreas produce more insulin and reduce glucagon production, which can help lower blood sugar levels; 2) Promote weight loss: GLP-1 agonists can slow down digestion, making people feel fuller for longer, and reducing appetite; 3) Reduce the risk of heart disease: Some studies suggest that GLP-1 agonists may lower the risk of heart disease and stroke; 4) They may have a role in reducing alcohol and drug use. All doses of each drug have the same price for 4 weekly injection pens, as cited from Goodrx.com, a discount coupon website. Semaglutide (Ozempic, Rybelsus, Wegovy by Novo Nordisk): $1000 Liraglutide (Victoza, Saxenda) by Novo Nordisc: $325 Dulaglutide (Trulicity) by Lilly: $853 Exenatide (Byetta, Bydureon) by Astra Zeneca: $796 Tirzepatide (Mounjaro) by Lilly: $1035 The costs elsewhere for 4 weekly pen injectorss are: Germany $328, Japan $169, the U.K. $93, Australia $87, France $83.·No doubt these amounts are highy profitable, since the cost of a pen is around $5. What these companies fail to understand is the lesson taught in high school economics. If the price is lower, the demand will go up, as will total revenue and profit. The likelihood of the clustering of these high prices by chance is very low in the absence of collusion. Why wouldn’t a competitor price a product $200 lower, and corner the market, while still making a high profit? Please, investigate the coincidence of these high prices. See they if they violate Antitrust Guidelines for Collaborations Among Competitors, the Sherman Act (15 U.S.C. § 1), the Clayton Act (15 U.S.C. § 14), the Federal Trade Commission Act (15 U.S.C. § 45), or state and federal laws prohibit price-fixing and collusion, such as the California Cartwright Act and the New York Donnelly Act. I understand, you cannot permit importation without new legislation. That leaves an investigation for collusion to lower the prices. Here are the addresses of the corporate counsels. Anat Hakim, Corporate Counsel Eli Lilly and Company Lilly Corporate Center 893 S. Delaware St. Indianapolis, IN 46285 Jesper Hoiland, General Counsel, North America Novo Nordisk Inc. 800 Scudders Mill Road Plainsboro, NJ 08536 Christine Tramontano, Chief Counsel, North America AstraZeneca Pharmaceuticals LP 1800 Concord Pike Wilmington, DE 19803