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Summit Nutritionals International, Inc is an international nutraceutical company founded by Caesar DePaço, Ph.D. in 2001.

Summit Nutritionals International, Inc. was founded in the United States to provide a source of chondroitin sulfate free of bovine spongiform encephalopathy (BSE) from avian, porcine, bovine and marine sources.

US Headquarters
Summit Nutritionals International, Inc includes a USA headquarters located in New Jersey and includes a plant / warehouse in Elizabeth, New Jersey as well. Summit Nutritionals produces about 400 tons of chondroitin sulfate per year and exports 30%-40% of its production to countries like Brazil, Germany, Mexico, the United Kingdom and Japan.

International
The International branch of Summit Nutritionals International, Inc is located in EU (Lisbon, Portugal).

Products
Summit Nutritionals International, Inc manufactures raw nutritional supplements including Droi-Kon, Chondroitin Sulfate, Cartilage Powder, Colostrum Powder and Hydrolyzed Collagen Powders for the global pharmaceutical industry.

Droi-Kon is a brand of chondroitin sulfate produced by Summit Nutritionals International, Inc. The brand name, “Droi-Kon” is owned by Summit Nutritionals International, Inc.

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Summit Nutritionals International vs. Sioux Pharm, Inc.
To The Honorable Judge of the Lisbon District Court

SUMMIT NUTRITIONAL INTERNATIONAL INC., branch in Portugal, Juristic Person Number 980413672, with its domicile in Lisbon, at Empreendimento Nova Amoreiras – Palácio- 3ºpiso, secção 9, Rua Artilharia 1, 71-77, 1250-038 Lisboa, Portugal

Hereby commences non-typified interlocutory injunction proceedings against, SIOUX PHARM INC., an American company with its registered office in 121 19th Street SW Sioux Center, IA 51250, Iowa, United States of America in the following terms and on the following grounds,

The Applicant, SUMMIT NUTRITIONALS INTERNATIONAL INC., is a commercial company, with its registered office in New Jersey, USA, which, via its branch in Portugal, is in the business of the commercialization in the European Union of chondroitine sulphate with the brand name DROI-KON, which it imports from the USA.

The product commercialized by the Applicant, SUMMIT NUTRITIONALS INTERNATIONAL INC., is food grade chondroitine sulphate, which is subject to a purity requirement that it must contain not less than 90% of chondroitine sulphate. There is also pharmaceutical grade chondroitine sulphate on the market, which must not only have the same minimum chondroitine sulphate content, but is also required to comply with certain requirements of the USP (USA Pharmacopeia). As clarified in the information attached as document no.1. which contents are incorporated by this reference.

The Applicant, SUMMIT NUTRITIONALS INTERNATIONAL INC., habitually acquires the product it commercializes from the manufacturer EAGLE LABORATORIES INC., whose plant is located in the State of IOWA in the USA.

The Respondent, SIOUX PHARM INC., is a commercial company with its registered office in the said state of IOWA, which is in the business of the manufacture and commercialization of pharmaceutical grade chondroitine sulphate under the CHONDROPURE brand name, among other products.

Food grade chondroitine sulphate is commercialized in Europe at a price between twenty and thirty euro/kilo, while the price of the pharmaceutical grade product is more than one hundred euro/kilo.

The product commercialized by the Applicant, SUMMIT NUTRITIONALS INTERNATIONAL INC., is submitted by it for analysis by laboratories accredited by the FDA - Food and Drug Administration in the USA, and these analyses have always shown the existence of at least 90% of chondroitine sulphate in the samples, i.e., the product’s required purity level. Certificate of analysis, and reports of 5 analysis referred in this certificate, are attached as document no.2 to 7, which contents are incorporated by this reference.

The Applicant’s clients in Europe, of which there are more than twenty, also conduct analyses of samples of the product supplied by the Applicant SUMMIT NUTRITIONALS INTERNATIONAL INC., at laboratories selected by them. As at the date hereof, none of the said clients have complained regarding the purity of the product and they have always expressed their total satisfaction with the quality of the product supplied by the Applicant, SUMMIT NUTRITIONALS INTERNATIONAL INC.

It is important to highlight that the Applicant, SUMMIT NUTRITIONALS INTERNATIONAL INC., acquired from the extremely demanding “Better Business Bureau Serving New Jersey”, the accreditation as a company that uses business practices according to ethics in advertisement, in sales and in commercial relationships with clients, as displayed in the certificate attached as document no.8, which contents are incorporated by this reference.

It is noteworthy that the methods of analysis appropriate to the analysis of the food grade product differ from those appropriate to the analysis of the pharmaceutical grade product. Furthermore, if analysis methods appropriate to the analysis of the pharmaceutical grade product are used to analyze the food grade product, the results obtained can show a purity level which is less than the required level.

In an industrial and commercial dispute with the Applicant's said supplier, the Respondent, SIOUX PHARM INC., commenced legal proceedings in IOWA in which it complains of acts of industrial espionage and of the adulteration of chondroitine sulphate by EAGLE LABORATORIES INC., via the addition of maltodextrin.

The Respondent, SIOUX PHARM INC., also claims in the said legal proceedings that the Applicant, SUMMIT NUTRITIONALS INTERNATIONAL INC., and another company, which is also a client of Eagle Laboratories, together with latter have diluted chondroitine sulphate with maltodextrin. This claim is manifestly untrue as the Respondent, SIOUX PHARM INC., is well aware that the Applicant, SUMMIT NUTRITIONALS INTERNATIONAL INC., is not a manufacturer and that it merely commercializes the product it acquires from manufacturers.

The Applicant, SUMMIT NUTRITIONALS INTERNATIONAL INC., has no reason to believe that its supplier EAGLE LABORATORIES INC. adulterates the product, but can assert that even if its said supplier is guilty of the said conduct, there is no adulteration of the product supplied to the Applicant, SUMMIT NUTRITIONALS INTERNATIONAL INC., as is clear from the analyses systematically carried out by both the Applicant, SUMMIT NUTRITIONALS INTERNATIONAL INC., and its clients.

On the false assumption that the Applicant, SUMMIT NUTRITIONALS INTERNATIONAL INC., commercialized an adulterated product and that it has contributed to the said adulteration, the Respondent, SIOUX PHARM INC., accuses the Applicant, SUMMIT NUTRITIONALS INTERNATIONAL INC., of unfair competition and seeks that damages be awarded against the Applicant, SUMMIT NUTRITIONALS INTERNATIONAL INC., with regard to the loss and damage suffered by the Respondent, SIOUX PHARM INC., which loss and damage it neither specifies not quantifies, and that the Applicant, SUMMIT NUTRITIONALS INTERNATIONAL INC., be freezed from diluting chondroitine sulphate and from distributing or selling diluted chondroitine sulphate, and further that the Applicant’s business in competition with the Respondent, SIOUX PHARM INC., be restrained or suspended at least while the proceedings are pending, which latter claim is manifestly excessive in the light of the facts pleaded.

The Respondent’s latter claim is a clear illustration of its real objective, which is to achieve a monopoly, or quasi-monopoly, in the market for the product in question, reduced to pharmaceutical grade, which is something that a remedy, which is merely corollary to the facts pleaded, i.e. that the Applicant, SUMMIT NUTRITIONALS INTERNATIONAL INC., be restrained from commercializing the adulterated product, would not permit it to achieve.

Given the fact that the Respondent, SIOUX PHARM INC., also commercializes its product in the EU, the Applicant, SUMMIT NUTRITIONALS INTERNATIONAL INC., has good reason to fear that the Respondent, SIOUX PHARM INC., which also has clients in this market, will seek to perturb the activity of the Applicant’s branch in Portugal, via false statements intended to discredit it, i.e. false descriptions of the quality of the product commercialized by the Applicant, SUMMIT NUTRITIONALS INTERNATIONAL INC., which amounts to anti-competitive conduct that is contrary to the honest custom and practice in any economic activity.

Given the great difference between the price of the product commercialized by the Respondent, SIOUX PHARM INC., and the product commercialized by the Applicant, SUMMIT NUTRITIONALS INTERNATIONAL INC., it is easy to comprehend the Respondent’s, SIOUX PHARM INC., interest in discrediting the Applicant, SUMMIT NUTRITIONALS INTERNATIONAL INC., or even in eliminating companies from the market that supply a market segment with a much lower prices, which will only have recourse to the Respondent’s, SIOUX PHARM INC., product, when the uses of the product or the requirements of the end clients cannot at all be satisfied by the food grade product.

Furthermore, the Respondent’s, SIOUX PHARM INC., conduct is not limited to this unfair competition, to which it has already had recourse in the legal proceedings in IOWA. The Respondent’s, SIOUX PHARM INC., greed is such that it adulterates its own product in order to increase its profits, not only by increasing its sales through the elimination of the Applicant, SUMMIT NUTRITIONALS INTERNATIONAL INC., from the market but also by reducing its production costs by adulteration of the product.

The adulteration of the Respondent’s, SIOUX PHARM INC., product, for which only the Respondent, SIOUX PHARM INC., can be responsible, was noted by the Applicant, SUMMIT NUTRITIONALS INTERNATIONAL INC., via an analysis of the contents of a package clearly identified as Chondropure, supplied by the Respondent, SIOUX PHARM INC..

This package was supplied by the Respondent, SIOUX PHARM INC., to a company that is also a food grade client of the Applicant, SUMMIT NUTRITIONALS INTERNATIONAL INC., and was made available by the said company for analysis by the Applicant, SUMMIT NUTRITIONALS INTERNATIONAL INC.

The analysis of the said product by an independent laboratory approved by the FDA, showed that the product supplied by the Respondent, SIOUX PHARM INC., does not even comply with the requirements applicable to the food grade product, as the chondroitine content of the product was only 24.90% and also does not comply with other requirements applicable to the pharmaceutical grade product, as result from the analysis report from the 4th March 2015, and from the identification of the analyzed sample, which are attached as documents no. 9 and no. 10 which contents are incorporated by reference.

By selling the said non-compliant product that lacks the required characteristics and does not meet the expectations of the Respondent’s, SIOUX PHARM INC., clients and lacks the characteristics announced by the Respondent, SIOUX PHARM INC., it is also guilty of unfair competition on the grounds of false description or incorrect indication of the product’s quality and use.

The Applicant, SUMMIT NUTRITIONALS INTERNATIONAL INC., is entitled to carry on its lawful and transparent economic activity in the European market in fair competition with the other operators in this market and to be protected from perturbations caused by operators that act in violation of the honest practices of this business.

The Respondent’s, SIOUX PHARM INC., stigmatized conduct causes the Applicant, SUMMIT NUTRITIONALS INTERNATIONAL INC., to fear that it will apply them in order to wrongfully interfere with and perturb its business in the European market.

The Applicant’s fear is amply justified by the Respondent’s, SIOUX PHARM INC., said conduct and fully justifies the grant of appropriate interlocutory injunctions in order to protect the Applicant’s threatened right.

In this case, the interlocutory injunctions sought are that the Respondent, SIOUX PHARM INC., be restrained from making any statements likely to discredit the Applicant, SUMMIT NUTRITIONALS INTERNATIONAL INC., and its product and that it be further restrained from introducing chondroitine sulphate into the European market that does not comply fully with the purity requirement of at least 90% of this product and that, in the case of pharmaceutical grade chondroitine sulphate, which does not comply with the other requirements applicable to that grade of product.

The risk of harm that the Applicant, SUMMIT NUTRITIONALS INTERNATIONAL INC., seeks to prevent is the risk that the Respondent, SIOUX PHARM INC., will cause irreparable harm, or harm that is difficult to remedy, to it, by affecting its reputation for honesty and the reputation of its product, by raising doubts as to the purity thereof, and that this will have an inevitable effect on the Applicant’s clients and is likely to result in a drastic reduction of its sales and in its replacement by competitors, which it would subsequently be difficult, if not impossible, to dislodge.

The said risk is not specifically provided for in any of the interlocutory injunctions typified in the law.

It is important to refer, due to the predictable behavior of the Respondent, SIOUX PHARM INC., not granting the protective order, matters to the Applicant, SUMMIT NUTRITIONALS INTERNATIONAL INC, who has always showed in its behavior transparency, strictness and the following the rules and honest practices of the branch of the commercial activity they are inserted, enormous damages, leading to a sales reduction and damaging its credibility in the market.

On another hand, from the granting of the protective order, which will not be more than demanding from the Respondent, SIOUX PHARM INC., acts accordingly to the honest practices of the practiced activity, mainly by avoiding the adulteration of the commercialized product, no damage, obviously can result to the Respondent, SIOUX PHARM INC.

Accordingly and on such other grounds as this Honorable Court finds on its own motion, the Respondent, SIOUX PHARM INC., should be restrained from making any statements likely to discredit the Applicant, SUMMIT NUTRITIONALS INTERNATIONAL INC., and its product and be further restrained from introducing Chondroitine Sulphate into the European market that does not comply fully with the purity requirement of at least 90% of this product and, in the case of pharmaceutical grade chondroitine sulphate, which does not comply with the other requirements applicable to that grade of product. The Applicant requests that this petition is served to the Defendant in the terms of the Hague Convention 15 November 1965 in order for the Defendant to oppose to this petition within the legal delay.

This protective order is requested as a preliminary to the action of condemnation of the Respondent, SIOUX PHARM INC; in the same terms requested in this petition.

Evidence:

Witness: Ana Santos, married, manager, with address at Empreendimento Nova Amoreiras, Palácio – 3º Piso/Secção 9 Rua Artilharia 1, 71-77, 1250-038 Lisboa, Portugal

The attorney Henrique Abecasis

Official Court Documents

http://sioux-pharm-inc.pissedconsumer.com/summit-nutritionals-international-vs-sioux-pharm-inc-sioux-falls-ia-20150319610631.html

https://drive.google.com/open?id=0BxwrutfOyLhCRFZCdFhJdzRLYWc&authuser=0

https://drive.google.com/open?id=0BxwrutfOyLhCMkRkNmRNMDlDM28&authuser=0

https://drive.google.com/open?id=0BxwrutfOyLhCMHVDOE9Qem80QzA&authuser=0

https://drive.google.com/open?id=0BxwrutfOyLhCaDg1NVZqSmJ3Z1E&authuser=0

https://drive.google.com/open?id=0BxwrutfOyLhCTWRwdHM5VzdUbkE&authuser=0