Iqbal, 556 U.S. at 678, 129 S.Ct. 1937 (citations omitted). And even before Iqbal, complaints had to “give the defendant fair notice of ... the grounds upon which it rests.” Conley v. Gibson, 355 U.S. 41, 47, 78 S.Ct. 99, 2 L.Ed.2d 80 (1957). The complaint in this case does not give the Generic Manufacturers “fair notice ... of the grounds upon which it rests,” or offer the “factual enhancement” necessary to pass Iqbal. It asserts without elaboration Plaintiffs’ belief that the Generic Manufacturers failed to update their warnings, providing no factual basis for that belief. As the district court noted, the belief is “pure conjecture.” The complaint is thus akin to Iqbal’s conclusory allegation that Ashcroft acted out of discriminatory motive, see 556 U.S. at 680-81, 129 S.Ct. 1937 (<HOLDING>), and to Twombly’s con-clusory allegation that
holding that the plaintiffs complaint failed to state a claim for purposeful and unlawful discrimination holding that 42 usc  1981 requires a showing of purposeful discrimination holding that plaintiffs complaint failed to state a claim under section 1 of the sherman act holding that although opponent of a peremptory challenge is not required to offer proof to establish purposeful discrimination failure to do so may impact on whether the party has carried its burden of persuasion to show purposeful discrimination holding that a violation of  1981 requires purposeful race discrimination