August 7, 2015
Ohio Attorney General Mike DeWine, Esq.
30 E. Broad St., 14th Floor
Columbus, OH 43215
Reference: Complaint No. 10291 and our prior letter of July 22, 2015
Dear Attorney General DeWine:
In our letter of July 22, 2015, we advised that Dr. Jeffrey Wadsworth the President and Chief Executive Officer of Battelle Memorial Institute was served a “Constructive Notice”, pursuant to §§ 1-308 (remedy), and; 1-103 (recourse) under common law as codified by the Uniform Commercial Code (UCC).
Dr. Wadsworth and Battelle Memorial Institute chose not rebut any of the facts as presented to them. These facts are now established as conclusive and dispositive facts in all subsequent matters of law in accordance with Uniform Commercial Code §1-205. In our prior letter we requested that you open a formal inquiry into the facts and take appropriate sanctions against Dr. Wadsworth and Battelle Memorial Institute.
Please be advised that the actions of Battelle Memorial Institute represent a pattern of behavior that goes well beyond our last report to you. Enclosed please find a Constructive Notice that is being served on the Secretary of Defense Ashton Carter that provides additional evidence that Mr. Wadsworth and Battelle Memorial Institute are engaging in a systematic scheme to misappropriate the intellectual property of small businesses. In this case, Battelle facilitated, in collusion with the U.S. Army, the theft and duplication of hydration, i.e., drinking, systems technology from a small business called Wesleyan Company.
To assist you further, please visit http://jgpis.org and click on the link, The Case of Wesleyan Company, for a detailed report provided to the Federal Bureau of Investigation with all supporting exhibits detailing the actions of Battelle Memorial Institute and others in this matter. In addition, you can access all of the exhibits sent to Secretary Carter that demonstrate a pattern of intellectual property theft by Battelle Memorial Institute.
In addition to violations of antitrust laws, we believe that Battelle Memorial Institute is operating as an enterprise that has exhibited a pattern of conduct that now makes them subject to the Racketeer Influenced and Corrupt Organizations Act.
If you wish to contact us for any reason please call at 240-439-4476 x-11. We stand ready to assist you in any and all ways possible. Thank-you for your efforts in protecting the citizens of Ohio and across the nation from predatory anticompetitive conduct.
John Hnatio, EdD, PhD
Jeffrey Wadsworth, BMI
Carter M. Stewart, Esq.
Vincent H. Cohen, Esq.
Rod J. Rosenstein, Esq.