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Quest Nutrition v. Board of Supervisors of LSU Agricultrual and Mechanical College, a Louisiana organization et. al.

Quest Nutrition v. Board of Supervisors of LSU Agricultrual and Mechanical College, a Louisiana organization et. al.

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Published by PriorSmart
Official Complaint for Declaratory Judgement in Civil Action No. 2:14-cv-02005: Quest Nutrition, LLC v. Board of Supervisors of LSU Agricultrual and Mechanical College, a Louisiana organization et. al. Filed in U.S. District Court for the Central District of California, no judge yet assigned. See http://news.priorsmart.com/-la6E for more info.
Official Complaint for Declaratory Judgement in Civil Action No. 2:14-cv-02005: Quest Nutrition, LLC v. Board of Supervisors of LSU Agricultrual and Mechanical College, a Louisiana organization et. al. Filed in U.S. District Court for the Central District of California, no judge yet assigned. See http://news.priorsmart.com/-la6E for more info.

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Published by: PriorSmart on Mar 16, 2014
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COMPLAINT
12345678910111213141516171819202122232425262728MARK P. WINE STATE BAR NO. 189897mwine@orrick.comKURT T. MULVILLE (STATE BAR NO. 149218)kmulville@orrick.comMARK J. SHEAN (STATE BAR NO. 217671)mshean@orrick.comJAMES MAUNE (STATE BAR NO. 293923) jmaune@orrick.comORRICK, HERRINGTON & SUTCLIFFE LLP2050 Main StreetSuite 1100Irvine, California 92614-8255Telephone: +1-949-567-6700Facsimile: +1-949-567-6710Attorneys for Plaintiff QUEST NUTRITION, LLCUNITED STATES DISTRICT COURTCENTRAL DISTRICT OF CALIFORNIAQUEST NUTRITION, LLC,Plaintiff,v.BOARD OF SUPERVISORS OF LSUAGRICULTURAL ANDMECHANICAL COLLEGE, aLouisiana organization; LSUAGRICULTURAL CENTER, aLouisiana organization; and WILLIAMRICHARDSON, ROBERTYARBOROUGH, ANN DUPLESSIS,GARRET DANOS, SCOTTBALLARD, STANLEY JACOBS, J.STEPHEN PERRY, SCOTTANGELLE, JOHN GEORGE,RAYMOND LASSEIGNE, R. BLAKECHATELAIN, JAMES MOORE, JR.,RONALD ANDERSON, ROLFEMCCOLLISTER, JR., JACK LAWTON, JR., LEE MALLETT, asindividuals and in their officialcapacities,Defendants.Case No.
COMPLAINT FOR:1. DECLARATORY JUDGMENTFOR OWNERSHIP OFPATENT APPLICATION2. DECLARATORY JUDGMENTFOR CORRECTION OFINVENTORSHIP OF PATENTAPPLICATION3. PRELIMINARY INJUNCTIVERELIEF4. ACCOUNTING5. CONVERSION6. BREACH OF CONTRACT7. BREACH OF CONTRACT8. INDUCING BREACH OFCONTRACT9. UNFAIR COMPETITIONJURY TRIAL DEMANDED
 
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 COMPLAINT
12345678910111213141516171819202122232425262728Plaintiff, Quest Nutrition, LLC (“Quest Nutrition”), files this Complaintagainst the above-named defendants, Board of Supervisors of LSU Agricultural andMechanical College (“Board”), LSU Agricultural Center (“Agricultural Center”),William Richardson, Robert Yarborough, Ann Duplessis, Garret Danos, ScottBallard, Stanley Jacobs, Ann Duplessis, J. Stephen Perry, Scott Angelle, JohnGeorge, Raymond Lasseigne, R. Blake Chatelain, James Moore, Jr., RonaldAnderson, Rolfe McCollister, Jr., Jack Lawton, Jr., Lee Mallett (collectively,“Defendants”), and demanding a trial by jury, alleges as follows:
JURISDICTION AND VENUE
1. The Court has diversity jurisdiction over this action pursuant to 28U.S.C. § 1332, as well as subject matter jurisdiction over this action as it arisesunder the patent laws of United States Code, Title 35 and under the DeclaratoryJudgment Act, 28 U.S.C. § 2201. The Court also has pendent jurisdiction for thecommon law claims.2. This Court has jurisdiction over Defendants due to Defendant’s purposeful direction of activities to residents of California. In addition to thecontractual relationships created by Defendants and California corporations such asQuest Nutrition, on information and belief, Defendants Board and AgriculturalCenter have participated in conferences within the State of California, solicitedresearch contracts, funds, and volunteers within the State of California, and targetedadvertising to residents of the State of California and within this District.3. Venue is proper in this Court pursuant to 28 U.S.C. § 1391(b)(2) because a substantial part of the events or omissions giving rise to this dispute between the parties occurred and continue to occur in this judicial district.
THE PARTIES
4. Plaintiff Quest Nutrition is a California corporation with its principal place of business at 2233 East El Segundo Boulevard, El Segundo, California92045.
 
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 COMPLAINT
123456789101112131415161718192021222324252627285. On information and belief, Board has a principal place of business at6400 Perkins Road, Baton Rouge, Louisiana 70803.6. On information and belief, Agricultural Center has a principal place o business at 104 J. Norman Efferson Hall, Baton Rouge, Louisiana 70803.7. On information and belief, Defendant William Richardson is the VicePresident of Agriculture and Dean of the College of Agriculture. The College of Agriculture is located at 138 Martin D. Woodin Hall, Baton Rouge, Louisiana70803.8. On information and belief, Robert Yarborough, Ann Duplessis, GarretDanos, Scott Ballard, Stanley Jacobs, J. Stephen Perry, Scott Angelle, John George,Raymond Lasseigne, R. Blake Chatelain, James Moore, Jr., Ronald Anderson,Rolfe McCollister, Jr., Jack Lawton, Jr., and Chester Mallett comprise the Board of Supervisors for the Louisiana State University System. Each Defendant is sued inhis or her official capacity, and in his or her individual and personal capacity. TheOffice of the Board of Supervisors is located at 3810 W. Lakeshore Dr., Rm. 104,Baton Rouge, LA 70808.
FACTUAL ALLEGATIONS
9. Quest Nutrition is a leading supplier of high quality nutritional barsand food products that are targeted to active, health-conscious consumers seekingnutritional supplements, meal replacements, and/or specialized food products.During the course of its business, Quest Nutrition continuously searches for improved ingredients for its products and retains outside researchers to investigatenew ingredients and production methods.10. In the summer of 2013, Quest Nutrition contacted representatives of the Defendants Board and Agricultural Center to commission an investigation intoa potential new sweetener.11. On September 9, 2013, Quest Nutrition, Board, and AgriculturalCenter entered into a Confidentiality and Non-Disclosure Agreement (the

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