Antitrust Brief on Projectioneering v. the Food and Drug Administration, BATTELLE MEMORIAL INSTITUTE and the Grocery Manufacturers Association

Antitrust Brief on Projectioneering v. the Food and Drug Administration, BATTELLE MEMORIAL INSTITUTE and the Grocery Manufacturers Association[1]

JURISDICTION

  1. Jurisdiction rests with the Federal District Court pursuant to the Sherman Act, “The several district courts of the United States are invested with jurisdiction to prevent and restrain violations of sections 1 to 7 of this title; and it shall be the duty of the several United States attorneys, in their respective districts, under the direction of the Attorney General, to institute proceedings in equity to prevent and restrain such violations. (26 Stat. 209, 15 U.S.C., § 4)

THE PLAINTIFFS

  1. Projectioneering LLC is a Maryland-based company that owns valuable intellectual property called predictive analytics that is used to manage risk across the critical infrastructures of society. [AT EXHBIT 1]
  2. FoodQuestTQ LLC is a Maryland-based company that uses the valuable Projectioneering-owned predictive analytic technology under a license from Projectioneering LLC to manage risks across the food and agricultural critical infrastructure. [AT EXHBIT 2]

The Defendants

  1. The U.S. Government to include the Department of Health and Human Services and the Food and Drug Administration. [AT EXHIBIT 3]
  2. Battelle Memorial Institute as one of the world’s largest research and development organizations operating under IRS code 501 (c) 3 designation as a charitable, nonprofit organization. [AT EXHIBIT 4]
  3. The Grocery Manufacturer’s Association as the largest beverage and food trade association with over 300 food industry members operating under IRS code designation as a 501 (c) 6 nonprofit industry and trade association. [AT EXHIBIT 5]

Statute of Limitations

  1. April 22, 2015, is the first time that plaintiffs learned of a scheme by the defendants to collude in the anticompetitive conduct of price fixing and bid rigging in the violation of the Sherman, Clayton Acts and other antitrust laws.
  2. On April 22, 2015, the President of Projectioneering LLC attended a food industry conference sponsored by the Grocery Manufacturers Association (GMA). GMA is one of the largest food and beverage industry trade association with over 300 member food companies across the globe.
  3. At that conference Dr. Joseph Scimeca, Vice President of Global Regulatory & Scientific Affairs at Cargill, Inc., unveiled a GMA program in which GMA member companies are pooling their Association’s membership funds to build a series of predictive analytic food risk management tools. [AT EXHIBIT 6]
  4. Dr. Scimeca stated during the presentation that GMA was working in cooperation with Battelle Memorial Institute, one of the world’s largest non-profit research organizations to produce the predictive analytic tools that would be provided to GMA member food companies.
  5. The predictive analytic food risk management methods and tools described by Dr. Scimeca in his presentation are based on plaintiffs’ patented ideas and trade secrets that were originally misappropriated from plaintiffs by the FDA in December 2012. [AT EXHIBIT 7]

Case Overview

  1. In August of 2006, a doctoral student at The George Washington University (GWU) completed his dissertation on the use of predictive analytics across the critical infrastructures including food and agriculture, energy, transportation, communications, cyber, national security and others. [AT EXHIBIT 8]
  2. Predictive analytic technology allows you to project what may happen in the future by discerning patterns of behavior in complex operating systems and mathematically treating the information to project the probability of similar or dissimilar future behavior. This is accomplished by analyzing large masses of data, i.e., big data.
  3. Gartner has estimated that the use of big data including predictive analytic technology will drive a $212 billion information technology (IT) investment by the year 2016. [AT EXHIBIT 9]
  4. In June 2007, the GWU doctoral student obtained a USPTO pending patent on the predictive analytic technology invention as described in his doctoral dissertation. [AT EXHIBIT 10]
  5. In November 2007, the Food and Drug Administration wrote their plan for protecting the food and agriculture critical infrastructure, i.e., the “National Food Protection Plan.” The FDA plan plagiarized the inventor’s doctoral dissertation. [AT EXHIBIT 11]
  6. Over the period 2009 to 2012, FDA officials received a series of proprietary briefings from the inventor of the predictive analytic technology as it applied to the food and agriculture vertical. These briefing materials contained the inventor’s patented ideas and the trade secrets developed as he reduced his invention to practice for food and agricultural applications. [AT EXHIBIT 12] The briefings given to the FDA were provided under Title 18 U.S.C. § 1905 as business confidential information and were marked as containing proprietary information. [AT EXHIBIT 13]
  7. On March 25, 2009, the inventor submitted a proprietary unsolicited proposal to the FDA for the co-development of the inventor’s patented predictive analytic food risk management software. The unsolicited proposal contained the patented ideas and trade secret information the inventor developed as he reduced his invention to practice for the food and agriculture critical infrastructure. The unsolicited proposal presented to the FDA was provided under Title 18 U.S.C. § 1905 as business confidential information and was marked as containing proprietary information. The proposal was rejected by the FDA. [AT EXHIBIT 14] The patented ideas and trade secrets described in the proposal subsequently appeared in an FDA set of duplicated tools that were given to the food industry by the U.S. Government at no cost. [AT EXHIBIT 15]
  8. In October 2009, the former GWU student and patent owner started a computer software business using private venture capital to apply his invention to the food and agriculture critical infrastructure. The small start-up company was named FoodQuestTQ LLC. FoodQuestTQ LLC entered into a field of use license arrangement with Projectioneering LLC. Projectioneering LLC owns the patent for risk management across all critical infrastructure applications.
  9. From October 2009 through 2011, Projectioneering LLC, its shareholders and the owners of FoodQuestTQ LLC invested approximately $6 million of private investment capital to build a commercial suite of six integrated food risk management tools based on the USPTO patent pending predictive analytic technology. In January of 2012, the USPTO issued their final patent for the predictive analytic technology to the inventor and Projectioneering LLC. [AT EXHIBIT 16]
  10. On May 16, 2012, the FDA in collusion with Battelle Memorial Institute, their support contractor, executed a Military Interdepartmental Purchase Request (MIPR) from the Department of Defense Chemical and Biological Information Analysis Center (CBIAC) to fund a subcontract with a computer software company called Valbrea Technologies. [AT EXHIBIT 17]
  11. Valbrea Technologies was granted a non-competitive “pass through” subcontract to produce FDA’s “Food Defense Plan Builder” tool software. The Food Defense Plan Builder tool software contained the patented ideas and trade secrets developed by the inventor as he reduced his patent to practice across the food and agricultural critical infrastructure. [AT EXHIBIT 17]
  12. The misappropriation of Projectioneering-owned patented ideas and trade secret information by Battelle Memorial Institute (BMI) took the form of negative know-how resulting from the involvement of BMI as a support contractor to FDA. BMI colluded with the FDA to duplicate the small company’s patented predictive analytics technology. [AT EXHIBIT 18] BMI facilitated an illegal contract, on behalf of the FDA, via a “directed pass-through contract” through the Department of Defense to another vendor, i.e., Valbrea Technologies, to duplicate plaintiffs’ predictive analytic software that contained the misappropriated patented ideas and trade secrets of the inventor. [AT EXHIBIT 17]
  13. BMI unlawfully served as an “alternative vendor” that derived knowledge and processes from Projectioneering-owned intellectual property by virtue of their position as a support contractor to the FDA thereby tainting the alternative vendor’s process, i.e., Valbrea Technologies, as the poisoned fruit of the initial misappropriation. [AT EXHIBIT 19]
  14. In July 2012, FoodQuestTQ LLC launched their first major campaign to sell their integrated suite of computer software food risk management tools to the commercial food industry. Sales never materialized because of the FDA, BMI and Valbrea Technologies had already duplicated the small company’s suite of predictive computer analytic tools that were being given away by the FDA to the food industry free of charge. [AT EXHIBIT 20]
  15. In December 2012, FoodQuestTQ LLC discovered that the FDA had misappropriated their patented ideas and trade secrets and duplicated the company’s suite of predictive analytic computer tools. The FDA was giving away the duplicate tools to the food industry free of charge at their official U.S. Government web site. [AT EXHIBIT 21]
  16. On October 2, 2012, Mr. Jody Menikheim, head of FDA’s Food Defense Team, stated that their “Food Defense Plan Builder,” tool accomplished the same purpose as the inventor’s prior developed risk management software but was not as sophisticated. [AT EXHIBIT 22]
  17. In January 2013, FoodQuestTQ LLC complained to the Chief Counsel of the FDA that her agency was involved in violations of procurement, procurement integrity, and other civil and criminal laws. The FDA initially promised the small company that they would conduct a fair and objective review of the entire matter. Instead, the FDA moved from their promised position of mediator to mount a civil and criminal defense of the agency and the employees allegedly involved in wrongdoing. [AT EXHIBIT 23]
  18. In March 2013, faced with this conflict of interest FoodQuestTQ LLC filed a formal complaint with National Ombudsman for Small Business at the Small Business Administration (SBA). The SBA National Ombudsman for Small Business then colluded with the FDA to elevate the matter to the Office of General Counsel of the Department of Health and Humans Services (HHS).  The FDA is a sub-unit of HHS.  This action by the National Ombudsman for Small Business did nothing but cause the FDA Office of Chief Counsel and the HHS Office of General Counsel to “team-up” in their defense of the agencies and the U.S. Government and contractor employees involved. [AT EXHIBIT 24]
  19. Over the period March 2013 to April 2014, the FDA Office of Chief Counsel colluded with the Office of General Counsel to prepare their own report of the matter stating that there was no wrongdoing and falsely alleging that the FoodQuestTQ LLC refused to cooperate in their investigation. [AT EXHIBIT 25]
  20. After the FDA-HHS investigation, FDA was found to have spoliated hundreds of evidentiary documents to prevent their release under the Freedom of Information Act. [AT EXHIBIT 23] The two FDA and the HHS lead attorneys engaged in real and actual conflicts of interest contrary to U.S. Government ethics laws and the rules of professional conduct for practicing attorneys in the District of Columbia and Maryland. The HHS lead attorney obstructed justice by extending lawyer-client privilege to U.S. Government employees involved in the wrongdoing as part of an illegal investigation of the matter and other serious irregularities. [AT EXHIBIT 25]
  21. Over the period April 2014 to July 2015, FoodQuestTQ LLC prepared an exhaustive report at the request of the FBI[AT EXHIBIT 23]; filed complaints with the Inspector General HHS; the GAO; the U.S. Department of Justice including the FBI and the DOJ Office of Inspector General; the DOJ Antitrust Division; the Federal Trade Commission; the District of Columbia, Ohio and Maryland Offices of State Attorneys General; the U.S. Attorney for the District of Columbia; the Office of Bar Counsel for the District of Columbia. [AT EXHIBIT 26] In all cases, the agencies involved either did not respond; stated that they did not have jurisdiction, or; did not have the resources or the inclination to mount an investigation. The small company’s congressional representatives stated that they did not “get involved in legal matters” and refused to intercede. [AT EXHIBIT 27]
  22. On April 12, 2015, FoodQuestTQ LLC learned that Battelle Memorial Institute was colluding with the FDA and one of the nation’s largest beverage and food trade associations, the Grocery Manufacturer’s Association, to duplicate another one of the small company’s new predictive analytic products for combating food fraud. The new offering contained the same patented ideas and trades secrets that the inventor developed as he reduced his original suite of predictive analytic food risk management tools to practice. [AT EXHIBIT 6]
  23. On May 7, 2015, Dr. Stephen Ostroff, Acting Commissioner of the Food and Drug Administration (FDA), 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). The Constructive Notice served on Dr. Ostroff contained a sworn affidavit of truth that included 42 statements of fact and 26 exhibits of proof demonstrating that the FDA and HHS engaged in anticompetitive conduct in violation of Sherman and Clayton antitrust laws and other state and federal laws that directly harmed the plaintiffs and, in turn, the safety and health of all food consumers. [AT EXHBIIT 28]
  24. Dr. Ostroff was granted 45 days (15 more days than the 30 day limit codified under the law) in which to rebut the facts as presented to him in the affidavit. Dr. Ostroff chose not to rebut any of the facts thereby “defaulting” at 11:59 PM on June 21, 2015.  Default having occurred, the facts as set forth in the Constructive Notice are now established as conclusive and dispositive facts in all subsequent matters of law in accordance with Uniform Commercial Code §1-205 A copy of the affidavit of truth presented to Dr. Ostroff for rebuttal and all supporting exhibits can be viewed and downloaded for your use on-line at https://jgpis.org
  25. On June 1, 2015, Dr. Jeffrey Wadsworth, President of Battelle Memorial Institute, was personally served with a Constructive Notice that contained a sworn affidavit of truth that included 148 statements of fact and 46 exhibits of proof to demonstrate that BMI colluded with the FDA to engage in anticompetitive conduct in violation of Sherman antirust and other state and federal laws. The affidavit of truth and supporting exhibits demonstrated that Dr. Wadsworth and Battelle Memorial Institute engaged in anticompetitive conduct that directly harmed FoodQuestTQ LLC and the safety and health of all food consumers. [AT EXHIBIT 29]
  26. Dr. Wadsworth was granted 45 days (15 more days than the 30 day limit codified under the law) in which to rebut the facts as presented to him in the affidavit. Dr. Wadsworth and Battelle Memorial Institute chose not to rebut any of the facts as presented to them thereby “defaulting” at 11:59 PM on July 15, 2015.  Default having occurred, the facts as set forth in the Constructive Notice are now established as conclusive and dispositive facts in all subsequent matters of law in accordance with Uniform Commercial Code §1-205. A copy of the affidavit of truth presented to Dr. Wadsworth for rebuttal and all supporting exhibits can be viewed and downloaded for your use on-line at https://jgpis.org
  27. On June 3, 2015, Ms. Pamela G. Bailey, President of the Grocery Manufacturers Association (GMA), 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). The Constructive Notice contained a sworn affidavit of truth that included 95 statements of fact and 38 exhibits of proof to demonstrating that GMA engaged in anticompetitive conduct in violation of Sherman antirust and other state and federal laws. [AT EXHIBIT 30]
  28. Ms. Bailey was granted 45 days (15 more days than the 30 day limit codified under the law) in which to rebut the facts as presented to her in the affidavit. Ms. Bailey chose not rebut any of the facts as presented to them thereby “defaulting” at 11:59 PM on July 18, 2015.  Default having occurred, the facts as set forth in the Constructive Notice are now established as conclusive and dispositive facts in all subsequent matters of law in accordance with Uniform Commercial Code §1-205. A copy of the affidavit of truth presented to Ms. Bailey for rebuttal and all supporting exhibits can be viewed and downloaded on-line at https://jgpis.org
  29. Projectioneering LLC has since filed formal requests for civil and criminal review with the application of sanctions with the U.S. Attorney for the District of Columbia and the Attorney Generals of the States of Ohio and Maryland. [AT EXHIBIT 31]

How the Defendants Engaged in Anticompetitive Conduct

  1. Bid rigging is a form of fraud in which a commercial contract is promised only to one party. The FDA and BMI violated Federal procurement laws and colluded to award a non-competitive subcontract through DOD to Valbrea Technologies to duplicate plaintiffs’ products containing the misappropriated patented ideas and trade secrets owned by the plaintiffs. [AT EXHIBIT 32]
  2. The actions of the FDA, DOD and Battelle Memorial Institute constitute bid rigging because the FDA and BMI colluded with one another to award a contract for duplicating the plaintiffs’ products solely to a single company in the absence of open and fair competition. [AT EXHIBIT 32]
  3. The FDA, in collusion with their support contractor, BMI, circumvented U.S. fair and open competition laws to assure that one company was the sole awardee of the contract to facilitate the duplication and wide dissemination, i.e., diffusion, of plaintiffs’ predictive analytic patented ideas and trade secrets as embodied in FoodQuestTQ’s products. [AT EXHIBIT 32]
  4. Under the Federal Activities Inventory Reform Act (FAIR), P.L. 105-270, and implementing Office of Management and Budget Circular A-76, the production of food risk management computer automated tools are not an inherently governmental function. As such, the FoodQuestTQ LLC suite of computer automated food risk management tools are considered by law as “commercial goods and services,” that must be openly procured from the private sector by the FDA. [AT EXHIBIT 23]
  5. The Competition in Contracting Act (CICA) of 1984 (41 U.S.C. 253) governs competition in Federal procurement contracting. Any procurement contract not entered into through the use of procurement procedures expressly authorized by a particular statute is subject to CICA.  CICA requires that contracts be entered into after “full and open competition through the use of competitive procedures” unless certain circumstances exist that would permit agencies to use noncompetitive procedures. [AT EXHIBIT 23]
  6. There exist seven such circumstances permitting other than full and open competition. To exercise any such an exemption requires a rigorous and documented approval process before a Federal non-competitive contract can be let. The U.S. Government sought no such exemption in the matter of FoodQuestTQ LLC. [AT EXHIBIT 23]
  7. The Federal Acquisition Streamlining Act (FASA) of 1994 establishes a “preference” for the procurement of commercial items, which are generally not subject to full and open competition under CICA. The Federal Acquisition Reform Act (FARA) of 1996 amended the Federal Acquisition Regulation (FAR) to “ensure that the requirement to obtain full and open competition is implemented in a manner that is consistent with the need to efficiently fulfill the Government’s requirements.” [AT EXHIBIT 23]
  8. Open and fair competition for the computer automated food risk management tools desired by the FDA would not have negatively impacted the efficiency of the Agency’s operations. Moreover, in the case of FoodQuestTQ LLC, the pursuit of a sole source contract could have been accomplished quickly and efficiently. [AT EXHIBIT 23]
  9. Thus, the non-competitive “pass through” contract among the FDA, the Department of Defense, Battelle Memorial Institute and Valbrea Technologies was not necessary to efficiently fulfill the FDA’s mission requirements in the matter of FoodQuestTQ LLC. [AT EXHIBIT 23]
  10. Under the terms of Battelle Memorial Institute’s contract as a Federally Funded Research and Development Center (FFRDC) with the FDA they are required to develop a detailed subcontracting plan that is used whenever the prime contractor lets subcontracts to outside entities to do work on behalf of the U.S. Government. (See FBI Exhibit No. 67) As an FFRDC these subcontract rules must include specific process steps that the Federal prime contractor implements to assure that the letting of subcontracts do not represent unfair competition with small businesses. [AT EXHIBIT 23] 
  11. These requirements were not followed when the FDA allowed Battelle Memorial Institute to use Department of Defense funds and initiate a “by-pass” contract to a single company, i.e., Valbrea Technologies, to build the FDA Food Defense Plan Builder tool even when the agency was fully aware that a commercial alternative was already available and that they were using the plaintiffs’ misappropriated intellectual property. [AT EXHIBIT 23]
  12. By so doing, the FDA purposefully bypassed fair and open competition by turning to Battelle Memorial Institute to initiate a “pass through” subcontract for a single company, i.e., Valbrea Technologies, to duplicate FoodQuestTQ LLC computer automated risk management tools even though the U.S. Government was fully aware that the same, similar and, in fact, superior products were already being commercially sold. Documents demonstrating that the FDA was fully aware that they were duplicating FoodQuestTQ LLC products that accomplished the same or similar purpose appear at FBI Exhibit No. 49 of the report of the matter prepared at the request of the FBI. [AT EXHIBIT 23]
  13. The result of this collusion by FDA, and BMI assured that the contract to duplicate the FoodQuestTQ predictive analytic technology would be awarded only to one promised party—Valbrea Technologies. Bid rigging is a form of fraud in which a commercial contract is promised to only one party. Therefore, FDA, DOD, BMI and Valbrea Technologies engaged in bid rigging. [AT EXHIBIT 32]
  14. Price fixing is an agreement between participants on the same side in a market to buy, sell or maintain the price of a product only at a fixed price. Price fixing can involve any agreement between competitors to tamper with prices or price levels. FDA, and BMI colluded with one another to fix the price of plaintiffs’ predictive analytic technology at an initial $0 cost price level for the food industry. In this way, FDA could set the price level for the predictive analytic technology they misappropriated from plaintiff at no cost to the food industry to maintain and then build the FDA and BMI foothold in the technology field of predictive analytics. [AT EXHIBIT 32]
  15. FDA misappropriated the valuable plaintiff-owned predictive analytic software when plaintiff provided the FDA with several proprietary briefings that contained his patented ideas and trade secrets. The FDA misappropriation of the plaintiff’s proprietary information is a violation of Title 18 U.S.C. § 1905. [AT EXHIBIT 32]
  16. BMI, in their position as both a contractor to the FDA and DOD support contractor, colluded with FDA personnel to misappropriate the plaintiff-owned intellectual property and initiate an unlawful pass through contract to duplicate plaintiffs’ valuable products as part of a suite of inferior predictive analytic tools for food risk management that could be given to the food industry free of any charge. [AT EXHIBIT 32]
  17. This was done to broadly diffuse plaintiff’s core patented ideas and trade secrets in order to obfuscate the true ownership of the predictive analytic technology for exploitation by FDA, BMI and GMA. In this way, BMI positioned itself to exploit, free of charge, the predictive analytic technology that was misappropriated from plaintiff. These actions by the defendants served to maintain and build BMI’s existing foothold in the lucrative technology field of predictive analytics. [AT EXHIBIT 32]
  18. BMI has since become one of the key leaders in satisfying the rapidly growing market need for predictive analytic tools across all critical infrastructures through the diffusion and subsequent commercial exploitation of plaintiffs’ patented ideas and trade secrets as a generic enabling technology. A generic enabling technology is a publicly available base technology that can be refined and applied across a number of different applications and industry verticals in the absence of paying license fees. [AT EXHIBIT 32]
  19. GMA colluded with FDA and BMI in facilitating BMI’s foothold in the technology field of predictive analytics for the food industry. This was done by GMA to satisfy the desires of its FDA-regulated members for lower-cost methods to enhance profits by reducing the risk and avoiding the rising liability costs associated with food safety negligence. An initial fixed price for the use of plaintiffs’ predictive analytic technology at no cost satisfied the food industry’s desire for a low-cost solution to reduce their liability. [AT EXHIBIT 32]

How the Defendants’ Anticompetitive Conduct Directly Damaged the Plaintiff and the American Consumer

  1. The Food and Drug Administration (FDA), Battelle Memorial Institute (BMI) and the Grocery Manufacturer’s Association (GMA) damaged the plaintiff by engaging in the anticompetitive conduct of bid rigging and price fixing. [AT EXHIBIT 32]
  2. This bid rigging and price fixing resulted in two forms of direct damage to the plaintiffs.
  3. The outright extinction of FoodQuestTQ’s sales of their predictive analytic tools to the food industry. [AT EXHIBIT 32]
  4. The broad diffusion of plaintiff’s patented predictive analytic technology as a generic enabling technology for subsequent no cost exploitation by BMI across the entire range of predictive analytic applications across all critical infrastructures and for GMA and its food industry members for food and agricultural applications. [AT EXHIBIT 32]
  5. The Food and Drug Administration (FDA), Battelle Memorial Institute (BMI) and the Grocery Manufacturer’s Association (GMA) damaged food consumers by engaging in the anticompetitive conduct of bid rigging and price fixing. [AT EXHIBIT 32]
  6. This bid rigging and price fixing resulted in direct damage to the consumer in the following three ways.
  7. The FDA intentionally introduced an inferior food safety risk management product into the commercial marketplace when they knew a superior product was commercially available thereby threatening the public health and safety. [AT EXHIBIT 32]
  8. The anticompetitive conduct of FDA, BMI and GMA served to stifle innovation in the area of predictive analytics for food risk management by colluding to disallow open and fair competition and instead directing work solely to “favored” contractors, i.e., BMI and Valbrea Technologies. [AT EXHIBIT 32]
  9. The anticompetitive conduct of FDA, BMI and GMA served to artificially reduce the cost of food risk management predictive analytic tools by offering an inferior product that did not protect consumers as effectively as the already available commercially available products. FDA, BMI and GMA engaged in the anticompetitive conduct for the purpose of maintaining and increasing the profits of food companies. [AT EXHIBIT 32]
  10. FDA and their contractor BMI engaged in the anticompetitive conduct to maintain and build BMI’s existing foothold in the lucrative technology field of predictive analytics. The harm to the consumer comes from the fact that BMI was being unfairly positioned to have major control over the future predictive analytics market for food risk and other critical infrastructure applications. The cost to the consumer for predictive analytic tools is being artificially manipulated by BMI as the result of restricting the competitive field in predictive analytics. [AT EXHIBIT 32]

LIST OF EXHBITS

AT EXHIBIT 1: Projectioneering LLC

AT EXHIBIT 2: FoodQuestTQ LLC

AT EXHIBIT 3:  Department of Health and Human Services (HHS) and the Food and Drug Administration (FDA)

AT EXHIBIT 4: Battelle Memorial Institute (BMI)

AT EXHIBIT 5: Grocery Manufacturers Association (GMA)

AT EXHIBIT 6: GMA program to build predictive analytic food risk management tools

AT EXHIBIT 7: GMA program is based on plaintiffs’ patented ideas and trade secrets misappropriated by the FDA

AT EXHIBIT 8: GWU doctoral dissertation containing patented ideas

AT EXHIBIT 9: Gartner estimate of value of big data and predictive analytics

AT EXHIBIT 10: June 2007, USPTO pending patent on predictive analytic technology

AT EXHIBIT 11: FDA plagiarization of GWU doctoral dissertation

AT EXHIBIT 12: Proprietary briefings revealing inventor’s patented ideas and trade secrets to the FDA

AT EXHIBIT 13: Title 18 U.S.C. § 1905

AT EXHIBIT 14: Proprietary proposal to the FDA containing inventor’s patented ideas and trade secrets

AT EXHIBIT 15: FDA duplicated tools using inventor’s misappropriated patented ideas and trade secrets

AT EXHIBIT 16: Final patent for the predictive analytic technology issued by USPTO to the inventor

AT EXHIBIT 17: Military Interdepartmental Purchase Request (MIPR) to circumvent open and fair competition

AT EXHIBIT 18: BMI colluded with the FDA to duplicate the small company’s patented predictive analytics technology

AT EXHIBIT 19: BMI unlawfully served as an “alternative vendor”

AT EXHIBIT 20: You Tube: The Story of FoodQuestTQ

AT EXHIBIT 21: FDA U.S. Government website giving away duplicate tools to the food industry free of charge

AT EXHIBIT 22: FDA admission that their duplicated software accomplished the same purpose as the small company’s software

AT EXHIBIT 23: Report prepared at the request of the Federal Bureau of Investigation

AT EXHIBIT 24: FoodQuestTQ complaint to the Small Business Administration

AT EXHIBIT 25: HHS legal counsel’s report

AT EXHIBIT 26: FoodQuestTQ LLC requests for investigation

AT EXHIBIT 27: Members of Congress stated that they “do not get involved in legal matters”

AT EXHIBIT 28: Constructive Notice to Stephen Ostroff, Acting Commissioner, Food and Drug Administration

AT EXHIBIT 29: Constructive Notice to Jeffrey Wadsworth, President & CEO, Battelle Memorial Institute

AT EXHIBIT 30: Constructive Notice to Pamela G. Bailey, President of the Grocery Manufacturers Association

AT EXHIBIT 31: Formal requests for civil and criminal review of the matter filed by the plaintiffs

AT EXHIBIT 32: Report: “How the FDA, Battelle Memorial Institute and the Grocery Manufacturers Association are violating antitrust laws”

[1]   AS GUIDED BY:  THE U.S. DEPARTMENT OF JUSTICE ANTITRUST DIVISION MANUAL | FIFTH EDITION | LAST UPDATED APRIL 2015

70 downloads 1.0 brucebecker 11-08-2015 18:25 Download
58 downloads 1.0 brucebecker 11-08-2015 18:24 Download
67 downloads 1.0 brucebecker 11-08-2015 18:24 Download
65 downloads 1.0 brucebecker 11-08-2015 18:24 Download
63 downloads 1.0 brucebecker 11-08-2015 18:23 Download
74 downloads 1.0 brucebecker 11-08-2015 18:23 Download
66 downloads 1.0 brucebecker 11-08-2015 18:23 Download
75 downloads 1.0 brucebecker 11-08-2015 18:22 Download
67 downloads 1.0 brucebecker 11-08-2015 18:22 Download
61 downloads 1.0 brucebecker 11-08-2015 18:21 Download
64 downloads 1.0 brucebecker 11-08-2015 18:21 Download
55 downloads 1.0 brucebecker 11-08-2015 18:20 Download
77 downloads 1.0 brucebecker 11-08-2015 18:20 Download
68 downloads 1.0 brucebecker 11-08-2015 18:20 Download
63 downloads 1.0 brucebecker 11-08-2015 18:18 Download
65 downloads 1.0 brucebecker 11-08-2015 18:18 Download
69 downloads 1.0 brucebecker 11-08-2015 18:18 Download
60 downloads 1.0 brucebecker 11-08-2015 18:16 Download
48 downloads 1.0 brucebecker 11-08-2015 18:16 Download
62 downloads 1.0 brucebecker 11-08-2015 18:16 Download
97 downloads 1.0 brucebecker 11-08-2015 18:16 Download
60 downloads 1.0 brucebecker 11-08-2015 18:15 Download
50 downloads 1.0 brucebecker 11-08-2015 18:15 Download
64 downloads 1.0 brucebecker 11-08-2015 18:15 Download
60 downloads 1.0 brucebecker 11-08-2015 18:15 Download
52 downloads 1.0 brucebecker 11-08-2015 18:14 Download
62 downloads 1.0 brucebecker 11-08-2015 18:14 Download
55 downloads 1.0 brucebecker 11-08-2015 18:14 Download
50 downloads 1.0 brucebecker 11-08-2015 18:14 Download
73 downloads 1.0 brucebecker 11-08-2015 18:14 Download
59 downloads 1.0 brucebecker 11-08-2015 18:13 Download
51 downloads 1.0 brucebecker 11-08-2015 18:13 Download
66 downloads 1.0 brucebecker 11-08-2015 18:13 Download
56 downloads 1.0 brucebecker 11-08-2015 18:12 Download
59 downloads 1.0 brucebecker 11-08-2015 18:12 Download
63 downloads 1.0 brucebecker 11-08-2015 18:12 Download
61 downloads 1.0 brucebecker 11-08-2015 18:12 Download
57 downloads 1.0 brucebecker 11-08-2015 18:11 Download
64 downloads 1.0 brucebecker 11-08-2015 18:11 Download
51 downloads 1.0 brucebecker 11-08-2015 18:11 Download
56 downloads 1.0 brucebecker 11-08-2015 18:11 Download
111 downloads 1.0 brucebecker 11-08-2015 18:10 Download
48 downloads 1.0 brucebecker 11-08-2015 18:10 Download
49 downloads 1.0 brucebecker 11-08-2015 18:10 Download
55 downloads 1.0 brucebecker 11-08-2015 18:09 Download
49 downloads 1.0 brucebecker 11-08-2015 18:09 Download
43 downloads 1.0 brucebecker 11-08-2015 18:09 Download
54 downloads 1.0 brucebecker 11-08-2015 18:08 Download
44 downloads 1.0 brucebecker 11-08-2015 18:08 Download
48 downloads 1.0 brucebecker 11-08-2015 18:08 Download
47 downloads 1.0 brucebecker 11-08-2015 18:08 Download
41 downloads 1.0 brucebecker 11-08-2015 18:08 Download
44 downloads 1.0 brucebecker 11-08-2015 18:07 Download
46 downloads 1.0 brucebecker 11-08-2015 18:07 Download
41 downloads 1.0 brucebecker 11-08-2015 18:07 Download
39 downloads 1.0 brucebecker 11-08-2015 18:07 Download
52 downloads 1.0 brucebecker 11-08-2015 18:06 Download
63 downloads 1.0 brucebecker 11-08-2015 18:06 Download
54 downloads 1.0 brucebecker 11-08-2015 18:06 Download
39 downloads 1.0 brucebecker 11-08-2015 18:05 Download
38 downloads 1.0 brucebecker 11-08-2015 18:05 Download
49 downloads 1.0 brucebecker 11-08-2015 18:05 Download
36 downloads 1.0 brucebecker 11-08-2015 18:04 Download
47 downloads 1.0 brucebecker 11-08-2015 18:04 Download
37 downloads 1.0 brucebecker 11-08-2015 18:04 Download
41 downloads 1.0 brucebecker 11-08-2015 18:04 Download
35 downloads 1.0 brucebecker 11-08-2015 18:03 Download
40 downloads 1.0 brucebecker 11-08-2015 18:03 Download
41 downloads 1.0 brucebecker 11-08-2015 18:03 Download
51 downloads 1.0 brucebecker 11-08-2015 18:02 Download
39 downloads 1.0 brucebecker 11-08-2015 18:02 Download
41 downloads 1.0 brucebecker 11-08-2015 18:02 Download
43 downloads 1.0 brucebecker 11-08-2015 18:02 Download
44 downloads 1.0 brucebecker 11-08-2015 18:01 Download
36 downloads 1.0 brucebecker 11-08-2015 18:01 Download
35 downloads 1.0 brucebecker 11-08-2015 18:01 Download
43 downloads 1.0 brucebecker 11-08-2015 18:01 Download
36 downloads 1.0 brucebecker 11-08-2015 18:00 Download
30 downloads 1.0 brucebecker 11-08-2015 18:00 Download
32 downloads 1.0 brucebecker 11-08-2015 18:00 Download
24 downloads 1.0 brucebecker 11-08-2015 18:00 Download
33 downloads 1.0 brucebecker 11-08-2015 17:59 Download
32 downloads 1.0 brucebecker 11-08-2015 17:59 Download
37 downloads 1.0 brucebecker 11-08-2015 17:59 Download
31 downloads 1.0 brucebecker 11-08-2015 17:58 Download
29 downloads 1.0 brucebecker 11-08-2015 17:58 Download
22 downloads 1.0 brucebecker 11-08-2015 17:58 Download
38 downloads 1.0 brucebecker 11-08-2015 17:58 Download
29 downloads 1.0 brucebecker 11-08-2015 17:57 Download
45 downloads 1.0 brucebecker 11-08-2015 17:57 Download
37 downloads 1.0 brucebecker 11-08-2015 17:57 Download
36 downloads 1.0 brucebecker 11-08-2015 17:57 Download
32 downloads 1.0 brucebecker 11-08-2015 17:56 Download
34 downloads 1.0 brucebecker 11-08-2015 17:56 Download
30 downloads 1.0 brucebecker 11-08-2015 17:56 Download
29 downloads 1.0 brucebecker 11-08-2015 17:56 Download
40 downloads 1.0 brucebecker 11-08-2015 17:23 Download
35 downloads 1.0 brucebecker 11-08-2015 17:22 Download
28 downloads 1.0 brucebecker 11-08-2015 17:21 Download
41 downloads 1.0 brucebecker 11-08-2015 17:21 Download
34 downloads 1.0 brucebecker 11-08-2015 17:21 Download
34 downloads 1.0 brucebecker 11-08-2015 17:21 Download
38 downloads 1.0 brucebecker 11-08-2015 17:20 Download
46 downloads 1.0 brucebecker 11-08-2015 17:20 Download
36 downloads 1.0 brucebecker 11-08-2015 17:20 Download
52 downloads 1.0 brucebecker 11-08-2015 17:20 Download
41 downloads 1.0 brucebecker 11-08-2015 17:20 Download
39 downloads 1.0 brucebecker 11-08-2015 17:19 Download
46 downloads 1.0 brucebecker 11-08-2015 17:19 Download
36 downloads 1.0 brucebecker 11-08-2015 17:19 Download
38 downloads 1.0 brucebecker 11-08-2015 17:18 Download
34 downloads 1.0 brucebecker 11-08-2015 17:18 Download
42 downloads 1.0 brucebecker 11-08-2015 17:18 Download
30 downloads 1.0 brucebecker 11-08-2015 17:17 Download
47 downloads 1.0 brucebecker 11-08-2015 17:16 Download
35 downloads 1.0 brucebecker 11-08-2015 17:15 Download
33 downloads 1.0 brucebecker 11-08-2015 17:15 Download
46 downloads 1.0 brucebecker 11-08-2015 17:15 Download
41 downloads 1.0 brucebecker 11-08-2015 17:14 Download
38 downloads 1.0 brucebecker 11-08-2015 17:14 Download
31 downloads 1.0 brucebecker 11-08-2015 17:09 Download
35 downloads 1.0 brucebecker 11-08-2015 17:09 Download
37 downloads 1.0 brucebecker 11-08-2015 17:09 Download
37 downloads 1.0 brucebecker 11-08-2015 17:09 Download
34 downloads 1.0 brucebecker 11-08-2015 17:08 Download
27 downloads 1.0 brucebecker 11-08-2015 17:08 Download
36 downloads 1.0 brucebecker 11-08-2015 17:08 Download
31 downloads 1.0 brucebecker 11-08-2015 17:08 Download
34 downloads 1.0 brucebecker 11-08-2015 17:07 Download
42 downloads 1.0 brucebecker 11-08-2015 17:07 Download
34 downloads 1.0 brucebecker 11-08-2015 17:07 Download
38 downloads 1.0 brucebecker 11-08-2015 17:07 Download
35 downloads 1.0 brucebecker 11-08-2015 17:06 Download
31 downloads 1.0 brucebecker 11-08-2015 17:06 Download
32 downloads 1.0 brucebecker 11-08-2015 17:06 Download
32 downloads 1.0 brucebecker 11-08-2015 17:05 Download
33 downloads 1.0 brucebecker 11-08-2015 17:05 Download
33 downloads 1.0 brucebecker 11-08-2015 17:05 Download
36 downloads 1.0 brucebecker 11-08-2015 17:03 Download
39 downloads 1.0 brucebecker 11-08-2015 17:03 Download
46 downloads 1.0 brucebecker 11-08-2015 17:03 Download
43 downloads 1.0 brucebecker 11-08-2015 17:03 Download
31 downloads 1.0 brucebecker 11-08-2015 17:02 Download
31 downloads 1.0 brucebecker 11-08-2015 17:02 Download
35 downloads 1.0 brucebecker 11-08-2015 17:02 Download
34 downloads 1.0 brucebecker 11-08-2015 17:02 Download
33 downloads 1.0 brucebecker 11-08-2015 17:02 Download
34 downloads 1.0 brucebecker 11-08-2015 17:01 Download
31 downloads 1.0 brucebecker 11-08-2015 17:01 Download
38 downloads 1.0 brucebecker 11-08-2015 17:01 Download
35 downloads 1.0 brucebecker 11-08-2015 17:01 Download
27 downloads 1.0 brucebecker 11-08-2015 17:00 Download
30 downloads 1.0 brucebecker 11-08-2015 17:00 Download
36 downloads 1.0 brucebecker 11-08-2015 17:00 Download
27 downloads 1.0 brucebecker 11-08-2015 17:00 Download
36 downloads 1.0 brucebecker 11-08-2015 16:59 Download
31 downloads 1.0 brucebecker 11-08-2015 16:59 Download
42 downloads 1.0 brucebecker 11-08-2015 16:59 Download
32 downloads 1.0 brucebecker 11-08-2015 16:59 Download
29 downloads 1.0 brucebecker 11-08-2015 16:58 Download
35 downloads 1.0 brucebecker 11-08-2015 16:58 Download
37 downloads 1.0 brucebecker 11-08-2015 16:58 Download
35 downloads 1.0 brucebecker 11-08-2015 16:57 Download
29 downloads 1.0 brucebecker 11-08-2015 16:57 Download
32 downloads 1.0 brucebecker 11-08-2015 16:57 Download
32 downloads 1.0 brucebecker 11-08-2015 16:56 Download
30 downloads 1.0 brucebecker 11-08-2015 16:56 Download
33 downloads 1.0 brucebecker 11-08-2015 16:56 Download
24 downloads 1.0 brucebecker 11-08-2015 16:56 Download
28 downloads 1.0 brucebecker 11-08-2015 16:55 Download
29 downloads 1.0 brucebecker 11-08-2015 16:55 Download
33 downloads 1.0 brucebecker 11-08-2015 16:55 Download
30 downloads 1.0 brucebecker 11-08-2015 16:55 Download
30 downloads 1.0 brucebecker 11-08-2015 16:54 Download
22 downloads 1.0 brucebecker 11-08-2015 16:54 Download
27 downloads 1.0 brucebecker 11-08-2015 16:53 Download
19 downloads 1.0 brucebecker 11-08-2015 16:53 Download
24 downloads 1.0 brucebecker 11-08-2015 16:53 Download
32 downloads 1.0 brucebecker 11-08-2015 16:53 Download
26 downloads 1.0 brucebecker 11-08-2015 16:52 Download
21 downloads 1.0 brucebecker 11-08-2015 16:52 Download
23 downloads 1.0 brucebecker 11-08-2015 16:52 Download
32 downloads 1.0 brucebecker 11-08-2015 16:51 Download
28 downloads 1.0 brucebecker 11-08-2015 16:51 Download
30 downloads 1.0 brucebecker 11-08-2015 16:51 Download
23 downloads 1.0 brucebecker 11-08-2015 16:50 Download
26 downloads 1.0 brucebecker 11-08-2015 16:50 Download
33 downloads 1.0 brucebecker 11-08-2015 16:50 Download
28 downloads 1.0 brucebecker 11-08-2015 16:50 Download
26 downloads 1.0 brucebecker 11-08-2015 16:49 Download
21 downloads 1.0 brucebecker 11-08-2015 16:49 Download
40 downloads 1.0 brucebecker 11-08-2015 16:49 Download
33 downloads 1.0 brucebecker 11-08-2015 16:49 Download
27 downloads 1.0 brucebecker 11-08-2015 16:35 Download
37 downloads 1.0 brucebecker 11-08-2015 16:35 Download
34 downloads 1.0 brucebecker 11-08-2015 16:34 Download
37 downloads 1.0 brucebecker 11-08-2015 16:34 Download
30 downloads 1.0 brucebecker 11-08-2015 16:34 Download
25 downloads 1.0 brucebecker 11-08-2015 16:34 Download
30 downloads 1.0 brucebecker 11-08-2015 16:33 Download
33 downloads 1.0 brucebecker 11-08-2015 16:33 Download
32 downloads 1.0 brucebecker 11-08-2015 16:33 Download
28 downloads 1.0 brucebecker 11-08-2015 16:33 Download
30 downloads 1.0 brucebecker 11-08-2015 16:32 Download
34 downloads 1.0 brucebecker 11-08-2015 16:32 Download
30 downloads 1.0 brucebecker 11-08-2015 16:31 Download
27 downloads 1.0 brucebecker 11-08-2015 16:30 Download
32 downloads 1.0 brucebecker 11-08-2015 16:29 Download
34 downloads 1.0 brucebecker 11-08-2015 16:29 Download
28 downloads 1.0 brucebecker 11-08-2015 16:29 Download
41 downloads 1.0 brucebecker 11-08-2015 16:28 Download
31 downloads 1.0 brucebecker 11-08-2015 16:28 Download
28 downloads 1.0 brucebecker 11-08-2015 16:28 Download
40 downloads 1.0 brucebecker 11-08-2015 16:27 Download
28 downloads 1.0 brucebecker 11-08-2015 16:27 Download
28 downloads 1.0 brucebecker 11-08-2015 16:27 Download
31 downloads 1.0 brucebecker 11-08-2015 16:26 Download
37 downloads 1.0 brucebecker 11-08-2015 16:26 Download
33 downloads 1.0 brucebecker 11-08-2015 16:26 Download
42 downloads 1.0 brucebecker 11-08-2015 16:26 Download
33 downloads 1.0 brucebecker 11-08-2015 16:25 Download
33 downloads 1.0 brucebecker 11-08-2015 16:25 Download
38 downloads 1.0 brucebecker 11-08-2015 16:25 Download
34 downloads 1.0 brucebecker 11-08-2015 16:25 Download
29 downloads 1.0 brucebecker 11-08-2015 16:24 Download
29 downloads 1.0 brucebecker 11-08-2015 16:24 Download
29 downloads 1.0 brucebecker 11-08-2015 16:24 Download
30 downloads 1.0 brucebecker 11-08-2015 16:23 Download
24 downloads 1.0 brucebecker 11-08-2015 16:23 Download
36 downloads 1.0 brucebecker 11-08-2015 16:23 Download
38 downloads 1.0 brucebecker 11-08-2015 16:22 Download
24 downloads 1.0 brucebecker 11-08-2015 16:22 Download
33 downloads 1.0 brucebecker 11-08-2015 16:22 Download
25 downloads 1.0 brucebecker 11-08-2015 16:22 Download
25 downloads 1.0 brucebecker 11-08-2015 16:21 Download
28 downloads 1.0 brucebecker 11-08-2015 16:21 Download
22 downloads 1.0 brucebecker 11-08-2015 16:21 Download
21 downloads 1.0 brucebecker 11-08-2015 16:20 Download
25 downloads 1.0 brucebecker 11-08-2015 16:20 Download
24 downloads 1.0 brucebecker 11-08-2015 16:20 Download
22 downloads 1.0 brucebecker 11-08-2015 16:19 Download
26 downloads 1.0 brucebecker 11-08-2015 16:19 Download
35 downloads 1.0 brucebecker 11-08-2015 16:19 Download
30 downloads 1.0 brucebecker 11-08-2015 16:18 Download
27 downloads 1.0 brucebecker 11-08-2015 16:18 Download
22 downloads 1.0 brucebecker 11-08-2015 15:58 Download
25 downloads 1.0 brucebecker 11-08-2015 15:58 Download
37 downloads 1.0 brucebecker 11-08-2015 15:58 Download
36 downloads 1.0 brucebecker 11-08-2015 15:58 Download
25 downloads 1.0 brucebecker 11-08-2015 15:57 Download
33 downloads 1.0 brucebecker 11-08-2015 15:57 Download
21 downloads 1.0 brucebecker 11-08-2015 15:57 Download
34 downloads 1.0 brucebecker 11-08-2015 15:57 Download
23 downloads 1.0 brucebecker 11-08-2015 15:57 Download
26 downloads 1.0 brucebecker 11-08-2015 15:56 Download
21 downloads 1.0 brucebecker 11-08-2015 15:56 Download
28 downloads 1.0 brucebecker 11-08-2015 15:56 Download
26 downloads 1.0 brucebecker 11-08-2015 15:56 Download
35 downloads 1.0 brucebecker 11-08-2015 15:55 Download
24 downloads 1.0 brucebecker 11-08-2015 15:54 Download
31 downloads 1.0 brucebecker 11-08-2015 15:54 Download
29 downloads 1.0 brucebecker 11-08-2015 15:54 Download
36 downloads 1.0 brucebecker 11-08-2015 15:54 Download
26 downloads 1.0 brucebecker 11-08-2015 15:53 Download
36 downloads 1.0 brucebecker 11-08-2015 15:53 Download
34 downloads 1.0 brucebecker 11-08-2015 15:53 Download
37 downloads 1.0 brucebecker 11-08-2015 15:53 Download
26 downloads 1.0 brucebecker 11-08-2015 15:52 Download
31 downloads 1.0 brucebecker 11-08-2015 15:52 Download
29 downloads 1.0 brucebecker 11-08-2015 15:52 Download
36 downloads 1.0 brucebecker 11-08-2015 15:52 Download
28 downloads 1.0 brucebecker 11-08-2015 15:51 Download
33 downloads 1.0 brucebecker 11-08-2015 15:51 Download
27 downloads 1.0 brucebecker 11-08-2015 15:51 Download
27 downloads 1.0 brucebecker 11-08-2015 15:51 Download
36 downloads 1.0 brucebecker 11-08-2015 15:50 Download
25 downloads 1.0 brucebecker 11-08-2015 15:50 Download
25 downloads 1.0 brucebecker 11-08-2015 15:50 Download
24 downloads 1.0 brucebecker 11-08-2015 15:50 Download
24 downloads 1.0 brucebecker 11-08-2015 15:49 Download
25 downloads 1.0 brucebecker 11-08-2015 15:49 Download
53 downloads 1.0 brucebecker 11-08-2015 15:49 Download
35 downloads 1.0 brucebecker 11-08-2015 15:49 Download
36 downloads 1.0 brucebecker 11-08-2015 15:48 Download
30 downloads 1.0 brucebecker 11-08-2015 15:48 Download
34 downloads 1.0 brucebecker 11-08-2015 15:47 Download
24 downloads 1.0 brucebecker 11-08-2015 15:47 Download
24 downloads 1.0 brucebecker 11-08-2015 15:47 Download
24 downloads 1.0 brucebecker 11-08-2015 15:47 Download
32 downloads 1.0 brucebecker 11-08-2015 15:46 Download
28 downloads 1.0 brucebecker 11-08-2015 15:46 Download
27 downloads 1.0 brucebecker 11-08-2015 15:46 Download
31 downloads 1.0 brucebecker 11-08-2015 15:45 Download
27 downloads 1.0 brucebecker 11-08-2015 15:45 Download
28 downloads 1.0 brucebecker 11-08-2015 15:45 Download
31 downloads 1.0 brucebecker 11-08-2015 15:45 Download
29 downloads 1.0 brucebecker 11-08-2015 15:44 Download
30 downloads 1.0 brucebecker 11-08-2015 15:44 Download
27 downloads 1.0 brucebecker 11-08-2015 15:44 Download
42 downloads 1.0 brucebecker 11-08-2015 15:44 Download
43 downloads 1.0 brucebecker 11-08-2015 15:43 Download
25 downloads 1.0 brucebecker 11-08-2015 15:43 Download
35 downloads 1.0 brucebecker 11-08-2015 15:43 Download
34 downloads 1.0 brucebecker 11-08-2015 15:42 Download
38 downloads 1.0 brucebecker 11-08-2015 15:42 Download
40 downloads 1.0 brucebecker 11-08-2015 15:25 Download
43 downloads 1.0 brucebecker 11-08-2015 15:25 Download
36 downloads 1.0 brucebecker 11-08-2015 15:25 Download
36 downloads 1.0 brucebecker 11-08-2015 15:24 Download
36 downloads 1.0 brucebecker 11-08-2015 15:23 Download

Leave a Reply

Your email address will not be published. Required fields are marked *