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A phantom recall continues to haunt Johnson & Johnson.

An Oregon appeals court last week revived a 2011 lawsuit brought by state officials who claimed the health care giant exposed consumers to defective supplies of the Motrin pain reliever and violated the state’s unlawful trade practices act.


The move comes five years after J&J reached a deal with the federal government — known formally as a consent decree — to upgrade several manufacturing facilities in the wake of severe quality-control problems. Such agreements require companies to meet certain standards before the Food and Drug Administration will permit shipments to resume.

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