Eli Lilly’s Case Against Strive Compounding Dismissed: A Major Win for Compound Pharmacies

Dave Knapp
4 hours ago
3 min read

Original posted at obesity.news/ on Oct 08, 2025

The ruling out of Delaware today should send a wave of relief across the compounding world. Federal Judge Stephanos Bibas, known for his no-nonsense, plain-language opinions, just dismissed Eli Lilly’s lawsuit against Strive Compounding Pharmacy. The case was tossed for lack of personal jurisdiction, meaning Lilly sued in the wrong place.

That might sound procedural, but in this landscape it’s huge.

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For months, patients and pharmacies have watched Lilly’s campaign against compounders expand, case by case, state by state. The company’s legal strategy has been clear: argue that compounders are falsely marketing unapproved “tirzepatide” formulations and drag them into court for deceptive advertising. But Judge Bibas wasn’t having it.

He wrote that while Lilly can pursue these claims somewhere else, it can’t do it in Delaware just because Strive’s website is visible nationwide. “Even in our digital age,” Bibas said, “personal jurisdiction has real limits.

That single line should make compounders breathe a little easier.

Why This Matters

This ruling doesn’t erase the risk of future lawsuits, but it forces Lilly to fight on harder terrain. If Lilly wants to continue, it’ll have to file in Arizona where Strive is based, or another state where Strive has a clear presence. That’s a much heavier lift than filing in Delaware where so many corporate suits live and die.

Even more importantly, this opinion subtly undercuts Lilly’s effort to nationalize its enforcement through federal court opinions that could scare smaller compounders into silence. Bibas made clear that a company’s website alone isn’t enough to haul them into court across the country.

And that’s a big deal.

Because the truth is, compounding pharmacies are filling a gap, a gap left behind by drug shortages, insurance exclusions, and unaffordable pricing. Judge Bibas’s opinion actually acknowledges that reality: compounded medications exist because “for patients with allergies or unique needs that make FDA-approved medications unsuitable, compounded drugs are a godsend.

When a federal judge uses that kind of language in a case brought by Eli Lilly, it’s not just a legal technicality. It’s validation.

The Bigger Picture

We’re witnessing two very different Americas in obesity medicine. One where pharmaceutical giants dominate the market with exclusive rights, and another where compounding pharmacies fight to keep medications accessible when supply chains and insurance systems fail patients.

This ruling doesn’t end the war, but it’s a major win in the battle. It signals that the courts aren’t ready to rubber-stamp Big Pharma’s reach beyond the states where they actually have a case. And for patients relying on compounded tirzepatide, it buys a little more time.

Zachary Shurtleff, CMO of Strive Pharmacy, provided this exclusive quote to OTP:

“We’re pleased to announce that Lilly’s case against Strive was dismissed today after the judge rejected Lilly’s attempt to forum shop and recognized that Lilly had no basis for forcing Strive to defend itself on the other side of the country (in Delaware?!).

We’re even more pleased that, in reaching that decision, the judge recognized what we all already know in this industry: that “For patients with allergies or unique needs that make FDA-approved medications unsuitable, compounded drugs are a godsend.

”We’re not sure what Lilly’s next move is. But we know what ours will be: fighting for the right of patients to keep their access to compounded drugs. Let’s do this!”

The Bottom Line

Eli Lilly can refile, and they likely will. But today, Strive, and by extension every compounding pharmacy trying to help patients afford their medications, just scored a major procedural victory that could ripple far beyond this one case.

The opinion closes with a line that could define the next phase of this fight:

“Eli Lilly has not pleaded that Strive targeted Delaware with its social media posts or website. Personal jurisdiction requires evidence of a real relationship.

In other words, this battle isn’t over, but the playing field just tilted a little closer to level.

Stay tuned to OnThePen.com for more updates and in-depth analysis on the latest developments in weight loss and diabetes treatments. Sharing this article is a powerful form of advocacy that brings us closer to our goal of educating the masses and reducing the stigma of obesity. If you found this article insightful, please share it within your networks, especially in Facebook groups and Reddit forums dedicated to GLP-1 medications and diabetes management. Together, we can make a difference.