The intersection of the Caremark and Park doctrines in Big Pharma

Interesting post by Paul E. Kalb  and Coleen Klasmeier on the intersection of the Caremark and "the Park doctrine, also known as the 'responsible corporate officer' doctrine, a line of federal cases holds that individuals who bear a 'responsible relation' to a violation of the Federal Food, Drug, and Cosmetic (FD&C) Act can be found criminally liable even without proof of traditional mens rea (guilty mind)."