While this filing is a departure from Waters & Kraus’ continuing practice of toxic exposure and cancer cases, the pattern and practice of improper conduct on the part of the defendants in this case rivals that of the asbestos corporate defendants and tobacco companies in other cases.

The suit states allegations based on fraud and conspiracy. From approximately 1955 through 1995, the exclusive or primary manufacturer and supplier of Ritalin in this country was defendant Ciba-Geigy Corp., U.S.A. ("Ciba"). In 1996 Ciba merged with Sandoz Pharmaceuticals Corp. to become defendant Novartis Pharmaceuticals Corp. ("Novartis"). Ciba/Novartis has manufactured, marketed and sold Ritalin since approximately 1955.

Ciba/Novartis planned, conspired, and colluded to create, develop and promote the diagnosis of Attention Deficit Disorder (ADD) and Attention Deficit Hyperactivity Disorder (ADHD) in a highly successful effort to increase the market for its product Ritalin. In addition to its actions and involvement with the creation of the ADD and ADHD diagnosis, Ciba/Novartis took steps to promote and dramatically increase the sales of Ritalin by way of the following:

1. Actively promoting and supporting the concept that a significant percentage of children suffer from a "disease" which required narcotic treatment/therapy;
2. Actively promoting Ritalin as the "drug of choice" to treat children diagnosed with ADD and ADHD:
3. Actively supporting groups such as Defendant CHADD, both financially and with other means, so that such organizations would promote and support (as a supposed neutral party) the ever-increasing implementation of ADD/ADHD diagnoses as well as directly increasing Ritalin sales;
4. Distributing misleading sales and promotional literature to parents, schools and other interested persons in a successful effort to further increase the number of diagnoses and the number of persons prescribed Ritalin.

Defendant CHADD (Children and Adults with Attention Deficit/Hyperactivity Disorder) has been a recipient of financial donations and contributions from Defendants Ciba/Novartis for many years. CHADD received $748,000 from Ciba/Novartis in the period 1991 to 1994 alone. During the periods when CHADD received funding from Ciba/Novartis, CHADD deliberately made efforts to increase the sales of Ritalin, and to increase the supply of methylphenidate (the generic name for Ritalin) available in the United States, and to reduce or eliminate laws and restrictions concerning the use of Ritalin and methylphenidate in the United States, all to the financial benefit of Ciba/Novartis. Ciba/Novartis made such financial contributions with the purpose of advertising and promoting sales of Ritalin – an internationally controlled substance. Ciba/Novartis has thus repeatedly violated Article 10 of the United Nations Convention on Psychotropic Substances, 1019 U.N.T.S. 175 (1971).

CHADD’s activities nationwide have led to significant increase in the amount of Ritalin taken by school children and have directly resulted in enormous profits to Ciba/Novartis.

Parents, the school districts and other interested parties are generally unaware that use of Ritalin can cause a significant number of health problems and risks, including but not limited to the following:

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