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IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF IOWA CENTRAL DIVISION

INTERNATIONAL STOCK FOOD CORPORATION Plaintiff, v. RIDLEY INC., and HUBBARD FEEDS, INC., Defendants.

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CIVIL ACTION NO.: 4:12-cv-98 COMPLAINT (JURY TRIAL DEMANDED)

Plaintiff, International Stock Food Corporation (ISF) files its Complaint against Defendants Ridley Inc. (Ridley) and Hubbard Feeds, Inc. (Hubbard) (collectively "Ridley Defendants") and avers as follows: PARTIES 1. Plaintiff ISF is a privately owned company organized and existing under the laws of the State of Georgia, and having its principal place of business at 1200 Buckhead Crossing, Woodstock, GA 30189. 2. On information and belief, Defendant Ridley Inc. is a corporation organized and existing under the laws of Canada with its U.S. headquarters located at 424 North Riverfront Drive, Mankato, Minnesota. 3. On information and belief, Defendant Hubbard Feeds, Inc. is the United States subsidiary of Ridley Inc. and is a corporation organized and existing under the laws of Minnesota with its principal place of business at 424 North Riverfront Drive, Mankato, Minnesota. 1

JURISDICTION AND VENUE 4. This is an action for patent infringement arising under the patent laws of the United States, 35 U.S.C. 1 et seq. 5. This Court has jurisdiction over the subject matter of this action pursuant to 28 U.S.C. 1331 and 1338(a). 6. Venue is proper in this district pursuant to 28 U.S.C. 1391(b), 1391(c), and 1400(b). Ridley Inc. and Hubbard Feeds, Inc. transact business directly and/or through third parties in this judicial district by manufacturing, using, selling, and offering to sell products for use in methods as described and claimed in ISFs U.S. Patent No. 6,610,341 (the '341 Patent) and/or by conducting other business in this judicial district. 7. The Ridley Defendants operate plants located throughout this district including at 2420 Old Highway 218 South, Iowa City, Iowa and at 60260 Marne Road, Atlantic, Iowa, and at other locations in Iowa. 8. On information and belief, the Ridley Defendants have been and continue doing business in this judicial district and others by manufacturing, marketing, selling and offering to sell their products. 9. The Ridley Defendants sell their products through at least dealers located at 2777 500th Street SW, Iowa City, Iowa; 2144 Old Hwy 218 S., Iowa City, Iowa; 313 Pleasant Street, Nichols, Iowa; 52246; and Hwy 22 West, Wellman, Iowa; 201 Cedar Street, Wilton, Iowa. FACTUAL ALLEGATIONS AND BACKGROUND 10. ISF develops, manufactures, markets and sells products for use in innovative methods of producing superior quality feed and forage for livestock. With over 60 years of experience and know-

how, ISF has been and continues to be a recognized leader and innovator in this field. 11. ISF has invested significant time, financial resources, and effort in the research and development of innovative feed and forage technologies. One such technology is ISF's patented method for preserving animal feed through application of a composition which arrests destructive effects of oxidation, and achieves reduced yeast and mold growth, longer bulk life and higher levels of retained nutrients in such feed. The compositions for use in ISF's patented method of preserving feed are made commercially available in a number of ISF products, including its ToxGuard products, for use by any persons and/or entities, such as feed manufacturers, seeking to produce quality feeds, with long shelf life. 12. ISF's method for preserving animal feed is patented in U.S. Patent No. 6,610,341 (the '341 Patent) entitled Method For Preserving Processed Grain And Animal Feed Comprising The Same. 13. The '341 Patent is entitled by statute to a presumption of validity. 14. The '341 Patent was duly and legally issued by the United States Patent and Trademark Office (USPTO) on August 26, 2003 and assigned to ISF by virtue of the assignment agreement between the inventor of the '341 Patent and ISF, of record at the USPTO. A true and correct copy of the '341 Patent is attached hereto as Exhibit 1. 15. On information and belief, the Ridley Defendants manufacture, market, and sell animal

nutrition and health products, including complete feed and premixes. 16. On information and belief, Ridley with and through its U.S. subsidiary, Hubbard Feeds,

Inc., manufactures, offers for sale and sells products, including but not limited to a product marketed as Bulletproof Bunk Stabilizer, for use and sale by others, including by its dealers in various states, for methods of preserving animal feeds which infringe the '341 Patent. 3

17.

The Ridley Defendants' Bulletproof Bunk Stabilizer directly competes with ISF's Tox

Guard product. 18. On information and belief, the Ridley Defendants have been and will continue to

manufacture animal feeds processed through use of Bulletproof Bunk Stabilizer according to preservation methods which infringe the '341 Patent, at least at the Hubbard plants located in Iowa City and Atlantic, Iowa. 19. On information and belief, the Ridley Defendants are planning to implement a

companywide protocol for manufacturing animal feeds so that all animal feeds manufactured in the Ridley Defendants' U.S. plants, including their Iowa City, Atlantic, Alta and Sioux City, Iowa plants, will be processed through use of Bulletproof Bunk Stabilizer according to preservation methods which infringe the '341 Patent. 20. On information and belief, the Ridley Defendants were aware of and had knowledge of

the 341 Patent, prior to the acts complained of herein. COUNT I (Infringement of the 341 Patent) 21. ISF incorporates by reference Paragraphs 1-20 of this Complaint as though fully set forth

herein. This cause of action arises under the patent laws of the United States, 35 U.S.C. 1 et seq. 22. On information and belief, the Ridley Defendants have infringed and continue to infringe

the '341 Patent by making, using and selling and/or offering for sale in the United States, animal feeds preserved according to the methods of the '341 Patent, in violation of 35 U.S.C. 271(a). 23. On information and belief, the Ridley Defendants have infringed and continue to infringe

the '341 Patent by making, using and selling and/or offering for sale in the United States, products which

induce others to make and use animal feeds preserved according to the methods of the '341 Patent, in violation of 35 U.S.C. 271(b). 24. Court. 25. On information and belief, the Ridley Defendants' infringement of the '341 Patent has The Ridley Defendants will continue to infringe the '341 Patent unless enjoined by this

been and continues to be willful and deliberate. 26. As a result of the Ridley Defendants' infringement of the '341 Patent, ISF has been and

continues to be damaged in an amount yet to be determined.

PRAYER FOR RELIEF WHEREFORE, ISF prays that this Court grant the following relief: 1. Judgment on this Complaint in its favor and against the Ridley Defendants for the above-

mentioned acts of infringement of the '341 Patent in violation of 35 U.S.C. 271(a); 2. Judgment on this Complaint in its favor and against the Ridley Defendants for the above-

mentioned acts of infringement of the '341 Patent in violation of 35 U.S.C. 271(b); 3. 4. A declaration that the Ridley Defendants infringement of the '341 Patent is willful; A preliminary and a permanent injunction against the Ridley Defendants and all those in

privity, association and/or concert with them from further infringement of the '341 Patent; 5. 6. A declaration that this is an exceptional case pursuant to 35 U.S.C. 285; An award of reasonable attorneys' fees and taxable costs in view of the intentional and

willful nature of the Ridley Defendants' patent infringement, rendering this an exceptional case pursuant

to 35 U.S.C. 285; 7. Such further relief as this Court deems just and appropriate. DEMAND FOR JURY TRIAL ISF hereby requests a jury trial on all issues.

Dated: March 2, 2012

_____ Richard Stefani GRAY, STEFANI & MITVALSKY, P.L.C. 200 American Building P.O. Box 456 Cedar Rapids, IA 52406 Phone: (319) 364-1535 Mark Boland Chandran B. Iyer Renita S. Rathinam SUGHRUE MION, PLLC 2100 Pennsylvania Ave. NW Washington, DC 20037 Telephone: (202) 293-7060 John B. Scherling SUGHRUE MION, PLLC 4250 Executive Square, Suite 900 La Jolla, CA 92037 Telephone: (858) 795-1195 Attorneys for Plaintiff International Stock Feed Corporation

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