Mylan N.V.
Mylan EpiPen Pricing Scandal
Estimated impact: $465M DOJ settlement; market share loss to generics
Mylan raised the price of the EpiPen from $57 to $609 (a 400%+ increase) over eight years while CEO Heather Bresch's compensation grew to $19M. The pricing exploited the product's life-saving monopoly status and lack of generic alternatives.
Decision context
Whether to continue systematic annual price increases on a life-saving product with no therapeutic alternatives, and whether the pricing strategy was sustainable politically and commercially.
Decision anatomy
Red = risk factor present · Green = protective factor present
Biases present in the decision
★ Primary driver · Severity estimated from bias type and decision outcome
Toxic combinations
Reference class base rates
Across all 143 curated case studies in our library:
Lessons learned
- Anchoring to annual price increase percentages rather than absolute cost to patients created a trajectory that became politically unsustainable
- Loss aversion: once high prices were embedded in revenue forecasts, any reduction felt like a loss rather than normalization
- Hindsight bias: the pricing was publicly available for years before it became a political issue — the risk was always present
Source: U.S. Senate Special Committee on Aging hearing (2016); DOJ settlement (2017) (News Investigation)
We caught these patterns in Mylan N.V.'s own record — before the outcome.
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Workflows that fire on decisions like Mylan N.V.’s
The same Recognition-Rigor Framework that documents this case audits memos in the same shape — before the outcome forces the lesson.