Medical Device Litigation

Cook IVC Filter Litigation: MDL 2570 Status and Court Record

Federal claims that Cook IVC filters fractured, tilted or perforated are consolidated as MDL 2570. The court record, FDA data and open questions.

Inferior vena cava filter devices and federal court records, the subject of the Cook IVC filter litigation
Inferior vena cava filter devices and federal court records, the subject of the Cook IVC filter litigation
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The Cook IVC filter litigation is a federal multidistrict proceeding about inferior vena cava filters, small devices placed in the large vein that returns blood to the heart. The Judicial Panel on Multidistrict Litigation transferred 27 actions from 11 districts to the Southern District of Indiana in an order dated October 15, 2014, creating MDL No. 2570 before Judge Richard L. Young. The panel’s October 1, 2026 report lists 6,470 actions pending and 11,478 filed. Two Seventh Circuit decisions have addressed when claims may proceed; neither decided whether a Cook filter was defective or caused an injury.

What the device is and what the cases allege

An IVC filter sits in the inferior vena cava, the large vein carrying blood from the lower body to the heart. The Southern District of Indiana describes it as placed there to catch blood clots before they reach the heart or lungs, and says the cases generally allege defective design, misrepresentation in marketing, and failure to warn.

The order described the claims as alleging that design defects made Cook’s filters more likely to fracture, migrate, tilt, or perforate the inferior vena cava, causing injury.

What is established vs. what is alleged

Established by the court record

  • The consolidation exists. The panel transferred 27 actions from 11 districts to the Southern District of Indiana before Judge Young. The master docket is 1:14-ml-2570-RLY-TAB, with Magistrate Judge Tim A. Baker also assigned (case information).
  • The case count is published. The panel’s October 1, 2026 report lists 6,470 actions now pending and 11,478 total actions (JPML report).
  • One appeal concerned choice of law. In Looper v. Cook Incorporated, decided December 16, 2021, the Seventh Circuit reversed the dismissal of two cases that plaintiffs had filed directly in the MDL court instead of their home states. It held that Cook had consented to the originating states’ choice-of-law rules, so the suits were timely under home-state law (Looper).
  • Another appeal concerned timeliness. In Gehner v. Cook Medical, decided July 30, 2024, the Seventh Circuit affirmed summary judgment for Cook on an Ohio plaintiff’s claims. The claims accrued in March 2013, when her doctors told her the filter had perforated her vena cava and compressed her small bowel, and the May 2016 suit was outside Ohio’s two-year period (Gehner).

Alleged in the complaints

The central allegation is that design defects made Cook’s filters prone to fracture, migration, tilt, or perforation of the inferior vena cava, and that patients were injured as a result. The cases also include claims that Cook misrepresented the devices in marketing and failed to warn doctors and patients. Those are allegations, not findings. Neither appellate decision reached whether the filters were defective, whether Cook was negligent, or whether a filter caused any patient’s injury.

Where the claims stand procedurally

MDL 2570 remains on the panel’s pending list. An MDL is not a trial or a class action: it consolidates pretrial proceedings before one judge, mainly discovery, expert challenges, and dispositive motions, while each plaintiff keeps a separate case. MDL versus class action explains the difference.

The two appeals show how procedural questions can end or revive cases without a ruling on the device. Looper concerned plaintiffs who filed directly in Indiana and faced its two-year period instead of three years in their home states. Gehner turned on an Ohio plaintiff’s own affidavit about when she learned of the injury. Both left the merits open.

No trial verdict in MDL 2570 appears in the documents reviewed for this article, and no global settlement or court-approved resolution appears either. The 6,470 figure counts actions not yet closed or remanded; it does not measure progress or merit.

The FDA record for Cook’s filters

The FDA’s device records show clearances and two recalls for the filter sets in the litigation.

  • Celect Platinum clearance, 2012. The FDA cleared K121629 for the Cook Celect Platinum Vena Cava Filter Set on July 3, 2012, with a decision description of “Substantially Equivalent.” The device is in product code DTK, class II (K121629).
  • Current sets, 2024. The FDA cleared K233680 on January 18, 2024 for the Celect Platinum and Günther Tulip set configurations, also with a decision description of “Substantially Equivalent” (K233680).
  • Celect Platinum recall, 2019. Cook initiated a Class III recall of the Celect Platinum sets on February 25, 2019, covering 91,731 units. The stated reason was updates to the instructions for use. The recall is listed as terminated on September 29, 2020 (Z-1026-2019).
  • Günther Tulip recall, 2022. Cook initiated a Class III recall of the Günther Tulip sets on February 14, 2022, covering 24,641 units. The reason was an instructions-for-use update covering the device description, indications, contraindications, warnings, precautions, and potential adverse events. The recall is listed as terminated on November 7, 2024 (Z-0875-2022).

Both are Class III and give an instructions-for-use update as the reason. Neither identifies a patient injury. A clearance record states a substantial-equivalence decision, not a finding on the alleged injuries.

Key dates

  • July 3, 2012: The FDA clears K121629 for the Cook Celect Platinum Vena Cava Filter Set.
  • October 15, 2014: The JPML transfers 27 actions from 11 districts to the Southern District of Indiana, creating MDL 2570 before Judge Young.
  • February 25, 2019: Cook begins the Class III Celect Platinum recall.
  • December 16, 2021: The Seventh Circuit reverses dismissals in Looper on choice-of-law grounds.
  • February 14, 2022: Cook begins the Class III Günther Tulip recall.
  • January 18, 2024: The FDA clears K233680 for the current Celect Platinum and Günther Tulip sets.
  • July 30, 2024: The Seventh Circuit affirms summary judgment for Cook in Gehner.
  • October 1, 2026: The JPML reports 6,470 actions pending and 11,478 filed in MDL 2570.

What this does not establish

The record reviewed here contains no judicial finding that a Cook IVC filter was defective or caused any patient’s injury. Looper and Gehner addressed choice of law and timeliness, not the merits. The FDA clearances are substantial-equivalence decisions, not approvals or safety findings for every use. The recalls concern instructions for use, and a recall record is not a finding that a device caused an injury. The pending count does not show that any claim is strong or that payment is available, and no settlement, verdict, or court-approved compensation programme appears in the documents reviewed.

Frequently asked questions

Is the Cook IVC filter litigation a class action?

No. Individual plaintiffs keep separate cases consolidated for pretrial purposes. See MDL versus class action.

Has a court found that Cook IVC filters are defective?

Not in the documents reviewed. The Seventh Circuit decisions cited here resolved choice-of-law and limitations questions, not defect or causation.

Did the FDA recall Cook IVC filters?

The FDA’s enforcement records list Class III recalls of the Celect Platinum sets in 2019 and the Günther Tulip sets in 2022. Both give instructions-for-use updates as the reason, and neither identifies a patient injury.

Can new Cook IVC filter cases still be filed?

MDL 2570 remains on the panel’s pending list as of October 1, 2026. Whether a particular person can file, and whether a claim would be timely, depends on state law and the facts. The statute of limitations guide explains the general framework. This article does not evaluate anyone’s claim.

Sources

  1. United States Judicial Panel on Multidistrict Litigation: “MDL Statistics Report - Distribution of Pending MDL Dockets by District” (link, accessed 2026-10-18)
  2. United States Judicial Panel on Multidistrict Litigation: “Transfer Order, In re Cook Medical, Inc., IVC Filters Marketing, Sales Practices and Products Liability Litigation, MDL No. 2570” (link, accessed 2026-10-18)
  3. United States District Court for the Southern District of Indiana: “MDL No. 2570 Case Information, In re Cook Medical, Inc., IVC Filters Marketing, Sales Practices and Products Liability Litigation” (link, accessed 2026-10-18)
  4. United States Court of Appeals for the Seventh Circuit: “Gehner v. Cook Medical, LLC, No. 23-3008 (7th Cir. July 30, 2024)” (link, accessed 2026-10-18)
  5. United States Court of Appeals for the Seventh Circuit: “Looper v. Cook Incorporated, No. 20-3103 (7th Cir. Dec. 16, 2021)” (link, accessed 2026-10-18)
  6. U.S. Food and Drug Administration: “510(k) Premarket Notification K121629, Cook Celect Platinum Vena Cava Filter Set” (link, accessed 2026-10-18)
  7. U.S. Food and Drug Administration: “510(k) Premarket Notification K233680, Celect Platinum and Gunther Tulip Vena Cava Filter Sets” (link, accessed 2026-10-18)
  8. U.S. Food and Drug Administration: “Device Enforcement Report Z-1026-2019, Cook Celect Platinum Vena Cava Filter Set” (link, accessed 2026-10-18)
  9. U.S. Food and Drug Administration: “Device Enforcement Report Z-0875-2022, Gunther Tulip Vena Cava Filter Set” (link, accessed 2026-10-18)

CollectiveClaim.us publishes general legal information. This article is not legal advice and does not create an attorney–client relationship. Court records and agency actions change; verify current status with the court or agency before relying on it.

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