IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF MARYLAND (NORTHERN DIVISION) __________________________________ TRAVCO PRODUCTS, INC.

) 2621 Bailey Road ) Forest Hill, Maryland 21050 ) ) Plaintiff, ) ) v. ) Case No. ____________________ ) WEDGEWOOD VILLAGE ) PHARMACY, INC. ) 405 Heron Drive, Suite 200 ) Swedesboro, New Jersey 08085 ) ) Serve On: ) George J. Malmberg ) 405 Heron Drive, Suite 200 ) Swedesboro, New Jersey 08085 ) ) Defendant. ) __________________________________ ) COMPLAINT FOR PATENT INFRINGEMENT Plaintiff, Travco Products, Inc. (Travco), by and through its undersigned attorneys, files this Complaint for patent infringement against the above-named Defendant Wedgewood Village Pharmacy, Inc. (Wedgewood), and in support alleges the following: THE PARTIES 1. Travco is a Maryland corporation with its principal place of business in Forest

Hill, Maryland. Travco distributes, sells, and has sold, nutritional supplement products across the United States, including Maryland. 2. On information and belief, Defendant Wedgewood is a business entity

incorporated and organized in the State of New Jersey with its principal place of business in Swedesboro, New Jersey. On further information and belief, Wedgewood manufactures

markets, offers to sell and/or does sell compounded animal drugs throughout the United States in the contiguous 48 States, including Maryland. JURISDICTION AND VENUE 3. This is an action for patent infringement of Untied States Patent No. 6,255,295

B1, a copy of which is attached hereto at Exhibit 1, brought under the provisions of the United States Patent Laws, Title 35 of the United States Code. Jurisdiction in this Court is therefore based upon 28 U.S.C. 1338(a). 4. Venue lies in this jurisdiction under 28 U.S.C. 1391 and 1400(b). FACTS 5. Travco is the assignee of United States Patent 6,255,295 B1 issued on July 3,

2001, entitled Aminosugar, Glycosaminoglycan or Glycosaminoglycan-like Compounds, and SAdenosylmethionine Composition for the Protection, Treatment, Repair, and Reduction of Inflammation of Connective Tissue (hereinafter, the 295 Patent). See Exh. 1. 6. Travco is the sole assignee of the entire right, title and interest in and to the 295

Patent with all rights pertaining thereto, including the right to bring this Civil Action and collect damages for infringement of the 295 Patent. 7. The 295 Patent contains the following two independent claims and eight

dependent claims: Claim 1. A composition for protection, treatment and repair of connective tissue and for reducing the inflammation of connective tissue in humans and animals comprising: glucosamine or glucosamine salts or mixtures thereof, in combination with pentosan polysulfate (PPS) or PPS salts or mixtures thereof. Claim 2. The composition of claim 1, wherein a dose of the glucosamine or glucosamine salts or mixtures thereof ranges from about 50 mg to about 40,000 mg. Claim 3. The composition of claim 1, wherein a dose of the glucosamine or glucosamine 2

salts or mixtures thereof for humans and small animals ranges from about 50 mg to about 5,000 mg. Claim 4. The composition of claim 1, wherein a dose of the glucosamine or glucosamine salts or mixtures thereof for large animals ranges from about 250 mg to about 40,000 mg. Claim 5. The composition of claim 1, wherein a dose of the pentosan polysulfate PPS or PPS salts or mixtures thereof ranges from about 15 mg to about 30,000 mg. Claim 6. The composition of claim 1, wherein the dose of pentosan polysulfate PPS or PPS salts or mixtures thereof for humans and small animals ranges from about 15 mg to about 5,000 mg. Claim 7. The composition of claim 1, wherein the dose of pentosan polysulfate PPS or PPS salts or mixtures thereof for large animals ranges from about 100 mg to about 30,000 mg. Claim 8. The composition of claim 1, wherein the salt of glucosamine is selected from the group consisting of glucosamine hydrochloride, glucosamine sulfate, and Nacetylglucosamine. Claim 9. The composition of claim 1, wherein the salt of PPS is selected from the group consisting of sodium PPS, calcium PPS or mixtures thereof. Claim 10. A method for the protection, treatment and repair of connective tissue and for reducing the inflammation of connective tissue in humans and animals comprising the step of administering any of the compositions of claim 1 through claim 7, or claim 9 to a human or an animal. 8. Defendant Wedgewood makes or has made, uses, offers to sell and sells a product

called Glucosamine/Pentosan: Injection Solution and a product called, Acetyl-DGlusoamine/Hyaluronic Acid/Pentosan: Injection Solution (together, the Products). 9. Wedgewood claims that its Products contain the ingredients Glucosamine and

Pentosan Polysulfate Sodium. 10. The product label for Glucosamine/Pentosan: Injection Solution further indicates

that the serving size of this product delivers 100 mg/ml of Glucosamine Sulfate and 250 mg/ml of Pentosan Polysulfate Sodium. 11. Glucosamine/Pentosan: Injection Solution is advertised and sold as a product to 3

be prescribed for horses. 12. The combination of Glucosamine Sulfate with Pentosan Polysulfate Sodium

contained in Wedgewoods Glucosamine/Pentosan: Injection Solution product infringes one or more of claims of the 295 Patent. 13. The Acetyl-D-Glucosamine/Hyaluronic Acid/Pentosan: Injection Solution

product comes in two strengths, one that is advertised to deliver 120 mg/ml of Acetyl-DGlucosamine and 75 mg/ml of Pentosan Polysulfate Sodium per injection, and another that is advertised to deliver 200 mg/ml of Acetyl-D-Glucosamine and 125 mg/ml of Pentosan Polysulfate Sodium per injection. 14. Both strengths of the Acetyl-D-Glucosamine/Hyaluronic Acid/Pentosan: Injection

Solution are advertised and sold as intended to be prescribed for horses. 15. The combination of Acetyl-D-Glucosamine with Pentosan Polysulfate Sodium

contained in both strengths of Wedgewoods Acetyl-D-Glucosamine/Hyaluronic Acid/Pentosan: Injection Solution product infringes one or more of claims of the 295 Patent. COUNT I DIRECT PATENT INFRINGEMENT 16. Travco incorporates by reference the allegations in Paragraphs 1 through 15 as if

stated fully herein. 17. Defendant Wedgewood has and continues to infringe the 295 Patent by making,

selling, offering to sell and distributing the Products, which contain a combination of ingredients that fall within the claims of the 295 Patent. 18. Defendant Wedgewoods infringement has damaged and is likely to continue to

damage Travco unless and until its infringing activities are enjoined by this Court. 19. Upon information and belief, Wedgewood has had actual or constructive notice of 4

the 295 Patent for several years. WHEREFORE, Plaintiff Travco prays the Court award it the following relief against Wedgewood: A. Damages pursuant 35 U.S.C. 284 that are adequate to compensate

Travco for the infringement, but in no event less than a reasonable royalty for the use made of the invention by each infringer, together with interest and costs; B. A permanent injunction that prohibits Defendant from making, using,

offering to sell or selling any product that infringes the 295 Patent; C. D. Enhanced damages to Travco as the court deems just; and Reasonable attorneys' fees pursuant to 35 U.S.C. 285. PRAYER FOR JURY TRIAL Plaintiff respectfully prays for a trial by jury on all issues so triable. Respectfully submitted,

/s/ Joshua A. Glikin (#26852) glikin@bowie-jensen.com Pamela K. Riewerts (#29423) riewerts@bowie-jensen.com BOWIE & JENSEN, LLC 29 W. Susquehanna Avenue, Suite 600 Towson, Maryland21204 Phone: (410) 583-2400 Facsimile: (410) 583-2437 Counsel for Plaintiff, Travco Products, Inc.