united states district court district of new jersey · 2015-12-05 · united states district court...

Case 2:11-cv-06976-WJM-MF Document 2 Filed 12/02/11 of 2 PagelD: 84

UNITED STATES DISTRICT COURT DISTRICT OF NEW JERSEY

LYNDA FROST, ET AL., Plaintiff

V. SUMMONS IN A CIVIL CASE

FIDOPHARM, INC., ET AL., Defendant

CASE NUMBER: 2:11—CV-06976—WJM—MF

TO: (Name and address of Defendant):

A lawsuit has been filed against you.

Within 21 days after service of this summons on you (not counting the day you received it) -- or 60 days if you are the United States or a United States Agency, or an office or employee of the United States described in Fed. R. civ. P. 12 (a)(2) or (3) -- you must serve on the plaintiff an answer to the attached complaint or a motion under rule 12 of the Federal Rules of Civil Procedure. The answer or motion must be served on the plaintiff or plaintiffs attorney, whose name and address are:

If you fail to respond, judgment by default will be entered against you for the relief demanded in the complaint. You also must file your answer or motion with the court.

WILLIAM T. WALSH

CLERK

DIANNE C. RICHARDS

(By) DEPUTY CLERK

ISSUED ON 2011-12-02 12:34:24.0, Clerk USDC NJD

Case 2:11-cv-06976-WJM-MF Document 2 Filed 12/02/11 of 2 PagelD: 85

RETURN OF SERVICE

Service of the Summons and complaint was made by me ID DATE

NAME OF SERVER (PRINT) TITLE

Check one box below to indicate appropriate method of service

10 Served personally upon the defendant. Place where served:

' Left copies thereof at the defendant's discretion then residing therein.

0 Name of person with whom the summons

0 Returned unexecuted:

dwelling house or usual place of abode with a person of suitable age and

and complaint were left:

0, Other (specify) :

STATEMENT OF SERVICE FEES TRAVEL SERVICES TOTAL

DECLARATION OF SERVER

I declare under penalty of perjury under the laws of the United States of America that the foregoing information contained in the Return of Service and Statement of Service Fees is true and correct.

Executed on Date Signature of Server

Address of Server

Case 2:11-cv-06976-WJM-MF Document 1 Filed 11/30/11 Page 1 of 25 PagelD: 1

COHN LIFLAND PEARLMAN HERRMANN & KNOPF LLP JEFFREY W. HERRMANN Park 80 Plaza West-One Saddle Brook, New Jersey 07663 Telephone (201) 845-9600

KANTROWITZ, GOLDHAMER & GRAIFMAN, P.C. GARY S. GRAIFMAN 210 Summit Avenue Montvale, New Jersey 07645 Telephone (201) 391-7000

GREEN & ASSOCIATES, LLC MICHAEL S. GREEN 522 Route 18, P.O. Box 428 East Brunswick, New Jersey 08816 Telephone (732) 390-0480

DIAMOND LAW OFFICE, LLC PAUL DIAMOND 1605 John Street, Suite 102 Fort Lee, New Jersey 07024 Telephone (201) 242-1110

Attorneys for Plaintiff

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF NEW JERSEY

LYNDA FROST and WILLIAM VALENTINE on behalf of themselves and all others similarly situated,

Plaintiff,

v. CIVIL ACTION

FIDOPHARM, INC., VELCERA, INC., CLASS ACTION COMPLAINT and WAL-MART STORES, INC. AND DEMAND FOR

JURY TRIAL Defendants.

CLASS ACTION

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Plaintiffs Lynda Frost and William Valentine, individually and on behalf of all others

similarly situated, by and through their attorneys, allege upon personal knowledge as to themselves

and upon information and belief as to the other allegations of this Complaint, as follows:

NATURE OF THE CASE

1. This is a class action pursuant to F.R.C.P 23, on behalf of all persons and entities

who purchased PetArmor manufactured, distributed, marketed and sold by Defendants, FidoPharm,

Inc., Velcera, Inc., and Wal-Mart Stores, Inc. (hereinafter, "Defendants").

2. Plaintiffs bring this class action for breach of express warranty, breach of implied

warranty of merchantability, unjust enrichment, the violation of the Florida Deceptive And Unfair

Trade Practices Act, Ark. Code Ann. §§ 4-88-101 to 4-88-207, the Arkansas Deceptive Trade

Practices Act, and Common Law Fraud to redress the economic damages resulting from the

manufacture, production and sale by the Defendants of the unsafe flea and tick Products, PetArmor

and PetArmor Plus for the Plaintiffs and Class Members and to secure preliminary and permanent

injunctive relief, and other equitable relief as may be deemed appropriate for the Plaintiffs and Class

Members.

3. As described in more detail below, Defendant FidoPharm, Inc. (hereinafter

"FidoPharm") has a principal place of business in Yardley, Pennsylvania. Defendant FidoPharm is

a wholly owned subsidiary of Velcera, Inc.

4. FidoPharm manufactures, produces and sells PetArmor and PetArmor Plus as a flea

and tick control "Product" for dogs and cats (hereinafter the "Product" or "Products"). PetArmor

contains the insecticide fipronil and PetArmor Plus contains fipronil and methoprene as active

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ingredients. PetArmor has the same active ingredients as Frontline which is manufactured by

Merial Limited. PetArmor was introduced into the marketplace on or about May, 2011 as a

"generic" brand of Frontline. FidoPharm states on its website that "the active ingredient in

PetArmor, fipronil, has been proven safe and effective in studies and over many years". Attached

hereto as Exhibit A is Defendant FidoPharm's website, www.petarmor.com containing this

statement. FidoPharm had, or should have had, knowledge of the adverse reactions that pets were

experiencing after the application of the fipronil products. The "Products" traditionally are

marketed and sold as packets with three separate applications in individual vials. Plaintiffs and

Class Members all purchased the "Products" and did not use all or some of the "Products" because

they are unsafe.

5. Defendant FidoPharm misrepresents that PetArmor does not enter the bloodstream

of the pet. Defendant FidoPharm claims on its website that PetArmor works the same way as

Frontline, "The active ingredient in PetArmor is fipronil (the same as in Frontline® Top Spot®)

PetArmor works the same way as Frontline Top Spot. PetArmor is just as safe and effective as

Frontline Top Spot." Attached as Exhibit B is Defendant FidoPharm's website,

www.petarmor.com containing this statement. Merial states on its website that Frontline is not

absorbed into the pet's bloodstream., "Frontline is absorbed into my dog's bloodstream isn't it? No.

Frontline is dispersed in the oil layer of the skin and then stored in the sebaceous glands of skin."

FidoPharm had, or should have had knowledge that fipronil in the PetArmor product is absorbed

into the bloodstream of the pet. Attached as Exhibit C is the statement on Merial's website.

6. The unsafe Products caused Plaintiffs and Class members monetary damages and

ascertainable losses, in that Plaintiffs and Class members purchased the "Products" and the

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"Products" failed to perform as advertised and are worth objectively less than what one could

reasonably expect.

7. Defendants knew or should have known that after application of these "Products" to

dogs and/or cats according to the product instructions and representations the Products caused

injury to said pets in that they became ill with central nervous system disorders/symptoms, rashes,

itching, hair loss and loss of appetite requiring veterinarians visits, hospitalizations, cessation of use

of remaining product and, in some cases, burials of those pets that died from complications caused

by the use of the PetArmor products.

8. The product is unsafe because it causes skin irritation and neurological problems

with greater severity and frequency than that cited in its misleading advertising and marketing.

Defendants' misrepresented the risk of use of the product to the public which was an

unconscionable commercial practice.

9. Defendant FidoPharm's advertising and marketing on the insert that comes with the

PetArmor product provides misleading advertising and marketing to consumers. Attached hereto

as Exhibit D is the insert. It reads:

"Sensitivities may occur after using ANY pesticide product for pets. While temporary

irritation at the application area may occur, if signs of continual sensitivity occur, consult a

veterinarian immediately."

PARTIES

10. Plaintiff Lynda Frost is a resident of Arkansas, having a place of residence in

Mabelvale, Arkansas.

11. Plaintiff William Valentine is a resident of Florida, having a place of residence in

Bunnell, Florida.

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12. Defendant, FidoPharm, Incorporated is a wholly owned subsidiary of Defendant

Velcera, Incorporated, and is a Delaware Corporation with its principal place of business in Yardley,

Pennsylvania. Defendant has and continues to have significant contacts with the State of New Jersey.

Among other things, defendant does business in the State of New Jersey, has a chain of distribution

in the State of New Jersey, and has derived and continues to derive significant revenue and income

from the residents of the State of New Jersey.

13. Defendant Velcera, Incorporated is a Delaware Corporation with its principal place

of business in Philadelphia, Pennsylvania.

14. Defendant Wal-Mart Stores, Inc. ("Wal-Mart") is a Delaware corporation with its

principle place of business at 702 S.W. 8 th Street, Bentonville, Arkansas, and local stores located at,

among other places, 150 Harrison Avenue, Kearny, New Jersey and 400 Park Place, Secaucus, New

Jersey.

15. Wal-Mart is the "Retailer Defendant". The Retailer Defendant is among the largest

retailers of pet supplies, including the products which form the subject matter of this action.

16. The Retailer Defendant has had, and continues to have, significant contacts with the

State of New Jersey. Among other things, defendant does business in the State of New Jersey, has

a chain of distribution in the State of New Jersey and has derived and continues to derive significant

revenue and income from residents of the State of New Jersey.

JURISDICTION AND VENUE

17. Venue is proper in this district pursuant to 28 U.S.C. §1391 because defendants

provided products and services to Class Members located in this district, and conducted substantial

business in this district. This Court has original jurisdiction over this class action under 28 U.S.C.

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§1332(d)(2), (d) (5)(B), (d) (6) because (i) there are 100 or more class members, (ii) there is an

aggregate amount in controversy of at least $5,000,000, exclusive of interest and costs, and (iii)

there is minimal diversity because Plaintiffs and Defendants are citizens of different states.

CLASS ACTION ALLEGATIONS

18. This action is brought and may properly proceed as a class action, pursuant to the

provisions of F.R.C.P. 23. Plaintiffs bring this action on behalf of themselves and all others

similarly situated. Proposed F.R.C.P 23(b)(3)Class is defined as follows:

All purchasers of PetArmor and PetArmor Plus products ("the products") for dogs and cats

between September 15, 2005 and the present who incurred economic damages as a result of not

using the remaining unsafe product they purchased.

Wal -Mart Class:

All purchasers of PetArmor and PetArmor Plus products ("the products") for dogs and cats between September 15, 2005 and the present who incurred economic damages as a result of not using the remaining unsafe product they purchased.

19. Plaintiffs further propose the following F.R.C.P 23(13)(2) Class for which injunctive

and declaratory relief only is sought. Plaintiffs seek to enjoin Defendant from selling the PetArmor

and PetArmor Plus products. This (b)(2) class is defined as follows:

All purchasers in the past and future of fipronil-containing PetArmor and PetArmor Plus products ("the products") in the United States for dogs and cats.

20. This action is properly maintainable as a class action. The class for whose benefit

this action is brought is so numerous and geographically dispersed that joinder of all members is

impracticable, and the disposition of their claims in a class action will provide substantial benefits

to both the parties and the Court. The numerosity requirement of F.R.C.P. 23(a)(1) is therefore

satisfied.

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21. A class action is superior to other methods for the fair and efficient adjudication of

the claims herein asserted, and no unusual difficulties are likely to be encountered in the

management of this class action. Since the damages suffered by individual class members may be

relatively small, the expense and burden of individual litigation makes it impossible for members

of the Class to individually seek redress for the wrongful conduct alleged.

22. Rule 23(a)(2) and Rule 23(b)(3) are both satisfied because there are questions of law

and fact which are common to the Class and which predominate over questions affecting any

individual class member. The common questions include, inter alia, the following:

a. Whether defendants breached any express or implied warranties when Defendants

Velcera and FidoPharm manufactured the unsafe product and Defendant Wal-Mart sold the unsafe

Product;

b. Whether defendants' business practices constitute violations of the violation of

the Arkansas Code Ann. §§ 4-88-101 to 4-88-207 Deceptive Trade Practices Act and the Florida

Stat. Ann. §§ 501.201 to 501.213 Deceptive And Unfair Trade Practices Act, and, if so, the measure

of damages and triple damages;

c. Whether defendant Wal-Mart has been unjustly enriched by its practices as

detailed herein;

d. Whether defendants Velcera and FidoPharm's products were not reasonably fit,

suitable or safe for their intended purpose because they were designed in a defective manner;

e. Whether defendants' actions were sufficiently wrongful so as to entitle Plaintiffs

and all others similarly situated to punitive damages; and,

f. Whether the Class has been damaged and/or suffered irreparable harm and, if so,

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the extent of such damages and/or the nature of the equitable and injunctive relief which each

member of the Class is entitled.

23. Plaintiffs' claims and the claims of members of the Class all derive from a common

nucleus of operative facts.

24. In satisfaction of F.R.C.P. 23(a)(3) and 23(a)(4), Plaintiffs are asserting claims that

are typical of the claims of the entire Class, and Plaintiffs will fairly and adequately represent and

protect the interests of the Class in that it has no interests that are antagonistic to those of the other

members of the Class. Plaintiffs anticipate no difficulty in the management of this litigation as a

Class action. Plaintiffs have retained counsel who are competent and experienced in the

prosecution of class action litigation.

25. Pursuant to F.R.C.P. 23(b)(1) and (b)(2), Defendants have acted or refused to act

on grounds generally applicable to the Class, making appropriate injunctive and declaratory relief

with respect to the proposed Class and subclass as a whole.

FACTUAL ALLEGATIONS

26. Defendant FidoPharm purports "that the active ingredient in Pet Armor, fipronil,

has been proven safe and effective in studies and over many years." Attached hereto as Exhibit

E is this statement found on PetArmor's website.

27. Defendant Wal-Mart sells PetArmor and PetArmor Plus at their retail stores and

on-line from their web-site, www.walmart.com . On Defendant's web-site, they have a statement

on their "Pet Supplies" home page stating, "Pets Love Wal-Mart. Top Brands to Keep Your Pet

Healthy, Active and Strong". Attached hereto as Exhibit F is the Wal-Mart web-site page.

Wal-Mart also advertises PetArmor with this phrase, "Keep Your Puppy Healthy for Less".

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Attached as Exhibit G is the web-site page. Wal-Mart states on its website that, "PetArmor for

Dogs up to 22 lb. provides the same #1 veterinarian-recommended active ingredient, Fipronil, in

the same concentration as Frontline. You get the same flea and tick protection as Frontline at a

significant savings."

28. PetArmor contains the insecticide fipronil and PetArmor Plus contains fipronil and

methoprene as active ingredients. Defendants began selling PetArmor on or about May, 2011.

FidoPharm is marketing and selling PetArmor as a newly available, low cost "version"of Frontline

tick and flea medication which is manufactured by Merial, Limited. FidoPharm represents that

PetArmor contains the same active ingredient as Frontline Attached hereto as Exhibit H is

FidoPharm's comparison of PetArmor to Frontline.

29. PetArmor is manufactured in India by Cipla, Limited. It was registered at the EPA

by LaredoChem, Incorporated. The EPA did not require any testing of PetArmor for registration

because FidoPharm submitted the previous testing that was completed for the Frontline product

registration. Attached hereto as Exhibit I is the EPA product registration application.

30. The current Chairman of Defendant Velcera, John Preston, was the founding

Executive Chairman of Merial. The Chief Executive Officer of Defendant Velcera, Dennis

Steadman, was Vice President of Operations at Merial. Attached hereto as Exhibit J is the Reuters

News Agency's biographies for Defendant Velcera's executives.

31. Prior to the introduction of PetArmor into the market, Frontline was the leading

seller of flea and tick medication. Attached hereto as Exhibit K is Merial's statement found on

their website as to their market share: "Merial produces 100 million pipettes of Frontline every

year" These insecticides are regulated and registered through the EPA and FDA. Any adverse

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reactions that are reported to the manufacturers must be then reported to the EPA.

32. The EPA issued an advisory on April 21, 2009 regarding the Flea and Tick Control

Products for Pets. This is attached hereto as Exhibit L. The EPA cited a recent sharp increase in

the number of adverse reactions that are being reported from the use of these products. Merial's

Frontline which contains the same active ingredient as PetArmor is one of the seven products that

comprise eighty percent (80%) of the 44,000 reported adverse reactions in 2008.

33. Petco advised consumers who were interested in purchasing flea and tick

medication through their website, www.petco.com , that the EPA has reported an increase in

complaints about these adverse reactions. Attached as Exhibit M is the www.petco.com advisory.

34. Defendant FidoPharm launched the sale of PetArmor in May, 2011, a full two years

after the EPA advisory of April 21, 2009. FidoPharm misrepresents that PetArmor does not enter

the bloodstream of the pets. FidoPharm makes the representation on its website that PetArmor

works the same way as Frontline. Merial represents that its product, Frontline is not absorbed into

the bloodstream. Many of the adverse reactions reported to the EPA involved systemic and serious

reactions and deaths after the use of Frontline. FidoPharm had, or should have had knowledge that

fipronil in the PetArmor product is absorbed into the bloodstream of the pet.

35. Notably, FidoPharm partnered with the American Society for the Prevention of

Cruelty to Animals ("ASPCA") to launch PetArmor. The ASPCA has selected PetArmor as their

"official" flea and tick treatment for dogs and cats at its adoption center and clinic. FidoPharm is

providing free PetArmor medication to the ASPCA and is donating up to $100,000 of support to

the ASPCA. Attached hereto as Exhibit N is Defendant FidoPharm's April 20, 2011 Press

Release.

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36. The ASPCA operates and owns the Animal Poison Control Center ("APCC"). This

is a twenty-four hour emergency poison hotline for pet owners and handles calls that specifically

pertain to flea and tick reactions in pets. The APCC charges a consultation fee of $65 for a call to

the hotline. The APCC also offers professional services to Animal Pharmaceutical corporations

through their APCC Animal Product Safety Service. The APCC will manage corporate clients'

adverse event reporting to the EPA and offers legal support, toxicology experts and consultation

on product liability. Attached hereto as Exhibit 0 is the list of services that the ASPCA Animal

Product Safety Service offers.

37. The Senior Vice President and head of the APCC is Dr. Steven R. Hanson. He was

the former Director of Veterinary Research for Wellmark International, a major manufacturer of

flea and tick medications Zodiac and BioSpot, which were also listed on the EPA Advisory of

April 21, 2009 (Exhibit H). In 2008, while working for the APCC, he was named the Veterinarian

of the Year which is an award sponsored Hartz Mountain Corporation which is another major

manufacturer of flea and tick medication. Hartz sells Hartz UltraGuard among others which is also

listed on the EPA Advisory of April 21, 2009.

38. During this time, Hartz Mountain Corporation was a client of the APCC. All calls

that came into the APCC regarding the Hartz products were redirected to Hartz Mountain

Corporation and the pet owner's $65 fee was waived, allowing Hartz to directly manage any of

these adverse event reports before they were to be reported to the EPA. Hartz also made major

donations to the ASPCA. Attached hereto as Exhibit P is the 2009 ASPCA Annual Report listing

Hartz Mountain Corporation as a Corporate donor.

39. On June 3, 2009, the ASPCA published a press release in response to the EPA

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issuing an advisory due to the increased reporting of adverse reactions to flea and tick medications.

In this press release, the ASPCA advised pet owners that these products are safe and that pet

owners should continue their use. Dr. Steven R. Hanson is quoted saying , "The important take

home message is that although adverse reactions can occur with all flea and tick products, most

effects are relatively mild and include skin irritation and stomach upset." and that "Pet Parents

should not discontinue using the products." Attached as Exhibit Q is the ASPCA press release.

Nowhere in the press release does it state that Dr. Hanson previously worked for a flea and tick

spot on medication manufacturer.

40. The ASPCA, and specifically the APCC, clearly have a relationship with the

manufacturers of the flea and tick medications. Simultaneously, they appear to the public to be an

independent organization representing the best interests of pet owners and their pets with respect

to flea and tick medications.

PLAINTIFFS' ALLEGATIONS

41. Plaintiff William Valentine owned two healthy cats. On or about August, 2011,

Plaintiff purchased PetArmor Plus for flea and tick control and applied it to his cat.

42. After the application of PetArmor Plus, the male cat became very sick and lethargic.

This cat eventually died. Plaintiff did not initially realize that it was the PetArmor that caused his

cat's death and proceeded to apply the product to his second cat. This cat had the same reaction to

the product as the Plaintiffs first cat.

43. Plaintiff called his veterinarian who advised him to wash the medication off the cat.

After that was done, the cat remained weak and lethargic.

44. Plaintiff Lynda Frost owned an eight year old dog named Sissy and a four year old

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cat named Tigger. Both pets were healthy with no medical problems. Plaintiff purchased the

PetArmor products at Wal-Mart for the purpose of flea and tick control.

45. Plaintiff applied PetArmor Plus to her cat on July 3, 2011. Tigger became lethargic,

had no appetite and would not even drink water. He normally loved to go outdoors but after the

application of PetArmor, Tigger doesn't want to leave the kitchen floor.

46. On July 15 th, 2011, Plaintiff Frost applied PetArmor to her dog Sissy. Five days

later, on July 20 th, 2011, Plaintiff found Sissy dead in her driveway.

FIRST COUNT

(Breach of Express Warranty)

47. Plaintiffs hereby incorporate by reference each of the preceding allegations as

though fully set forth herein.

48. Defendants FidoPharm, Velcera and Wal-Mart expressly warranted that the unsafe

pet Product was, in fact, a safe flea and tick Product for use on dogs and cats.

49. Defendant FidoPharm expressly warranted that the PetArmor product works the

same as the Frontline Product. FidoPharm state on its website that, "The active ingredient in

PetArmor is fipronil (the same as in Frontline® Top Spot®) PetArmor works the same way as

Frontline Top Spot. PetArmor is just as safe and effective as Frontline Top Spot." Merial, the

manufacturer of Frontline states on its website that Frontline is not absorbed into the pet's

bloodstream., "Frontline is absorbed into my dog's bloodstream isn't it? No. Frontline is dispersed

in the oil layer of the skin and then stored in the sebaceous glands of skin."

50. In addition, Defendants made numerous express warranties about the safety and

quality of its Product. For example, FidoPharm touts on their website the claim that "that the

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active ingredient in Pet Armor, fipronil, has been proven safe and effective in studies and over

many years.". Defendant Wal-Mart advertises PetArmor by stating, "Keep your Puppy Healthy for

Less" and that Wal-Mart's pet products, "keep your pet healthy, active and strong". The

Defendant's advertisings and marketing included on the insert with the PetArmor product are

inadequate as it indicates that adverse reactions were "temporary irritation".

51. Members of the Class were induced by Defendants' advertising and marketing of

the Product as being "proven safe", that adverse reactions were simply some "temporary irritation"

and that the Product "works the same way as Frontline" which has been misrepresented as not

entering the bloodstream Plaintiffs and the Class relied upon the express warranties created by

Defendants' statements, and did so rely in purchasing the unsafe Product and applying it to their

pets.

52. In reliance on Defendants' misrepresentations, Plaintiffs and the Class purchased

the PetArmor product and gave it to their pets.

53. By virtue thereof, as a direct and proximate cause of Defendants breach of Express

Warranty, Plaintiffs and Class Members have suffered damages in an amount to be determined

upon trial, which they are entitled to and hereby seek to recover.

54. Wherefore, as a result of Defendants' breach of Express Warranty, the Plaintiffs

and Class Members have suffered ascertainable losses and monetary damages in an amount to be

determined upon trial, which they hereby seek to recover when they were charged by the

defendants for the unsafe pet Product and were unable to use all of the Product.

SECOND COUNT (Breach of Implied Warranty of Merchantability)

55. Plaintiffs hereby incorporates by reference each of the preceding allegations as

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56. Defendants are merchants pursuant to sections 2-104 and 2-314 of the Uniform

Commercial Code with respect to pet Products.

57. Through Defendants' marketing, advertising and sales, Defendants impliedly

warranted that the unsafe pet Product, which was sold to Plaintiffs and Class Members and

administered to their pets, was fit for the ordinary purpose for which it was intended, namely, to

safely control flea and ticks on pets without any resulting negative health effects, pursuant to

section 2-3114 of the Uniform Commercial Code.

58. Through the Defendants' marketing, advertising, and sales, Defendants knew that

Plaintiffs and Class Members would purchase the unsafe pet Product at issue for the ordinary

purpose of treating flea and/or tick infestations of their pets.

59. Defendants manufactured, advertised, sold and distributed the unsafe pet Product at

issue for the ordinary purpose for which it was purchased by Plaintiffs.

60. Plaintiffs and Class Members purchased and used the unsafe pet Product for

ordinary purposes for which such goods are sold, namely to safely control flea and ticks on their

pets.

61. Plaintiffs and Class Members relied upon Defendants' representations and claims

in purchasing the unsafe pet Product.

62. The unsafe pet Product purchased by Plaintiffs and Class Members were unfit for

their ordinary purpose when sold. In fact, such pet Products were unsafe and caused severe illness

and/or death of the pets that used them. Defendant also warranted that the Product "works the

15


same way as Frontline" which has been misrepresented as not entering the bloodstream. Therefore,

Defendants breached the implied warranty of merchantability in the sale of the unsafe pet Product

at issue.

63. By virtue thereof, as a direct and proximate cause of Defendants breach of Implied

Warranty, Plaintiffs and Class Members sustained damages as a proximate result of said breach of

warranty and hereby seek to recover said damages and other monetary relief to which they may also

be entitled.

64. Wherefore, as a result of Defendants' breach of Implied Warranty, the Plaintiffs and

Class Members have suffered ascertainable losses and monetary damages in an amount to be

determined upon trial, which they hereby seek to recover when they were charged by the

defendants for the unsafe pet Product and were unable to use all of the Product.

THIRD COUNT

(Unjust Enrichment)



66. As set forth in greater detail above, Defendant profited and benefited from the sale

of their unsafe pet Product, even as the pet Product caused Plaintiffs and Class Members to incur

economic damages.

67. As a result of the conduct described in this Count, the Plaintiffs and Class Members

paid monies to Defendant for which the Plaintiffs and Class Members received no benefit and to

which Defendants were not entitled. Defendants have voluntarily accepted and retained these

profits and benefits, derived from consumers, including Plaintiffs, with full knowledge and

16


awareness that, as a result of Defendant's unconscionable wrongdoing, consumers, including

Plaintiffs, were not receiving products of the quality, nature, fitness or value that had been

represented by Defendant or that reasonable consumers expected.

68. In consequence of the acts set forth in this Count, Defendant have been unjustly

enriched at the expense of the Plaintiffs and Class Members.

69. The Plaintiffs and Class Members are entitled to the amount of Defendant's unjust

enrichment as restitution which is hereby sought.

FOURTH COUNT (Violations of the Arkansas Deceptive Trade Practices Act, Ark. Code Ann. §§ 4-88-101 to

4-88-207)



71. Defendants are the researchers, developers, designers, testers, manufacturers,

inspectors, distributors, advertisers, marketers and sellers and released the unsafe pet Product into

the stream of commerce while promoting its sales and use through advertising.

72. Defendants knew or should have known that the use of the unsafe pet Product

causes serious and life threatening injuries to animals with greater severity and frequency than

cited in its misleading advertising and marketing. The Defendants misrepresented that their

products were safe or safer than they actually are and these misrepresentations were an

unconscionable commercial practice. In addition, Defendants made material omissions when they

intentionally failed to inform Plaintiffs and consumers generally of the severity of side effects that

may occur from use of the "Products."

73. Defendant also represented that the Product "works the same way as Frontline"

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which has been misrepresented as not entering the bloodstream. FidoPharm knew or should have

had known that the fipronil in the PetArmor product is absorbed into the bloodstream of the pet.

This misrepresentation is an unconscionable commercial practice.

74. Plaintiffs and members of the Class suffered an ascertainable loss, the recovery of

which is hereby sought, when they were charged by the defendant for the unsafe pet Product and

were unable to use all of the Product.

75. The promotion and release of the unsafe pet Product into the stream of commerce

generally, and in particular, with misleading advertising and marketing, constitutes an

unconscionable commercial practice, deception, false pretence, misrepresentation, and/or

concealment, suppression or omission of material facts with the intent that others would rely upon

such concealment, suppression or omission in connection with the sale or advertisement of such

merchandise by Defendants, in violation of the Arkansas Deceptive Trade Practices Act, Ark.

Code Ann. §§ 4-88-101 to 4-88-207.

76. Wherefore, as a result of Defendants' violations of the Arkansas Deceptive Trade

Practices Act, Ark. Code Ann. §§ 4-88-101 to 4-88-207, Plaintiffs and Class Members have

suffered ascertainable losses and monetary damages in an amount to be determined upon trial,

which they hereby seek to recover when they were charged by the defendants for the unsafe pet

Product and were unable to use all of the Product.

77. By virtue thereof, class-wide injunctive relief is sought to enjoin Defendants from

selling the "Product" with their current misleading marketing and advertising.

FIFTH COUNT (Violations of the Florida Deceptive And

Unfair Trade Practices Act, Fla. Stat. Ann. §§ 501.201 to 501.213)

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Case 2:11-cv-06976-WJM-MF Document 1 Filed 11/30/11 Page 19 of 25 Pagel D: 19

78. Plaintiffs hereby incorporate by reference each of the preceding allegations as though

fully set forth herein.

79. Defendants are the researchers, developers, designers, testers, manufacturers,

inspectors, distributors, advertisers, marketers and sellers and released the unsafe pet Product into

the stream of commerce while promoting its sales and use through advertising.

80. Defendants knew or should have known that the use of the unsafe pet Product

causes serious and life threatening injuries to animals with greater severity and frequency than

cited in its misleading advertising and marketing. The Defendants misrepresented that their

products were safe or safer than they actually are and these misrepresentations were an

unconscionable commercial practice. In addition, Defendants made material omissions when they

intentionally failed to inform Plaintiffs and consumers generally of the severity of side effects that

may occur from use of the "Products."

81. Defendant also represented that the Product "works the same way as Frontline"

which has been misrepresented as not entering the bloodstream. FidoPharm knew or should have

had known that the fipronil in the PetArmor product is absorbed into the bloodstream of the pet.

This misrepresentation is an unconscionable commercial practice.

82. Plaintiffs and members of the Class suffered an ascertainable loss, the recovery of

which is hereby sought, when they were charged by the defendant for the unsafe pet Product and

were unable to use all of the Product.

83. The promotion and release of the unsafe pet Product into the stream of commerce

generally, and in particular, with misleading advertising and marketing, constitutes an

unconscionable commercial practice, deception, false pretence, misrepresentation, and/or

19


concealment, suppression or omission of material facts with the intent that others would rely upon

such concealment, suppression or omission in connection with the sale or advertisement of such

merchandise by Defendants, in violation of the Florida Deceptive And Unfair Trade Practices Act,

Fla. Stat. Ann. §§ 501.201 to 501.213.

84. Wherefore, as a result of Defendants' violations of the Florida Deceptive And

Unfair Trade Practices Act, Fla. Stat. Ann. §§ 501.201 to 501.213, Plaintiffs and Class Members

have suffered ascertainable losses and monetary damages in an amount to be determined upon trial,

which they hereby seek to recover when they were charged by the defendants for the unsafe pet

Product and were unable to use all of the Product.


selling the "Product" with their current misleading representations and warranties in their

marketing and advertising.

SIXTH COUNT Common Law Fraud



87. Defendants' misrepresentations and omissions of material facts set forth above

misled Plaintiffs and members of the Class and the general public.

88. In making the misrepresentations of fact described herein to Plaintiffs and members

of the Class and the general public, Defendants failed to fulfill its duty to disclose material facts set

forth above.

89. The misleading representations and warranties in Defendants' marketing and

advertising alleged herein to be improper and illegal, were intended to result in the sale of

20


Defendants' unsafe flea and tick Products, PetArmor and Pet Armor Plus to the consuming public.

90. As detailed herein, Defendants have or should have been aware at all relevant times

throughout the development, manufacture, distribution and sale of its flea and tick Products,

PetArmor and Pet Armor Plus, that the unsafe pet Product causes serious and life threatening

injuries to animals with greater severity and frequency than cited in its misleading advertising and

marketing. In addition, Defendants knew or reasonably should have known that consumers relied

on Defendants' representations and believed that these products were safe to use as marketed and

advertised, while also knowing that the unsafe flea and tick products alleged above causes serious

and life threatening injuries to animals with greater severity and frequency than cited in its

misleading advertising and marketing.

91. As detailed herein, Defendants have or should have been aware at all relevant times

throughout the development, manufacture, distribution and sale of its flea and tick Products,

PetArmor and Pet Armor Plus, that the unsafe pet Product is absorbed into the bloodstream of the

pets. In addition, Defendants knew or reasonably should have known that consumers relied on

Defendants' representations that PetArmor works the same way as Frontline and believed that the

product was not being absorbed into the bloodstream, while also knowing that the products alleged

above were misrepresented as not being absorbed into the bloodstream of the pets.

92. Plaintiff and the Class reasonably relied upon Defendants' misleading

representations and warranties in Defendants' marketing and advertising in making purchasing

decisions and ultimately deciding to purchase Defendants' unsafe flea and tick Products. As such,

Plaintiffs and the Class were fraudulently induced to purchase these unsafe flea and tick products.

93. These acts, omissions, misrepresentations, practices and non-disclosures by

21


Defendants as alleged herein constitute common law fraud under New Jersey common law and the

common law of each of the several United States.

94. As a result of Defendants' material misrepresentations and omissions, Plaintiffs

and Class Members have suffered ascertainable loss and damages in an amount to be determined

at trial, which they hereby seek to recover when they were charged by the defendants for the unsafe

pet Product and were unable to use all of the Product.


selling the "Product" with their current misleading representations and warranties in their

marketing and advertising.

SEVENTH COUNT (Declaratory Relief)



97. Plaintiffs and Class members seek Declaratory Relief declaring that:

a. The Defendants' misrepresented the risk of the use of the product to the

public because the product causes skin irritation and neurological problems with greater

severity and frequency than that cited in its misleading representations and warranties in

their marketing and advertising and that the Product "works the same way as Frontline"

which has been misrepresented as not entering the bloodstream. Defendants'

misrepresented the risk of use of the product to the public as deceptive, misleading and

unconscionable is a deceptive act and practice;

EIGHTH COUNT (Injunctive Relief)

22




99. Plaintiffs and Class members seek Injunctive Relief, enjoining Defendants from

continuing to sell the product with its misrepresentations as to the risk of the use of the product to

the public because the product causes skin irritation and neurological problems with greater severity

and frequency than that cited in its misleading representations and warranties in their marketing and

advertising and that the Product "works the same way as Frontline" which has been misrepresented

as not entering the bloodstream.

100. Plaintiffs and Class members have no adequate remedy at law.

101. By virtue thereof, the Class is entitled to injunctive relief.

WHEREFORE, Plaintiffs, on behalf of themselves and the members of the Class,

demand judgment as follows:

(a) A determination that this action is a proper class action maintainable under Federal

Rules of Civil Procedure, Rule 23, and certifying an appropriate Class and/or Subclass and

certifying Plaintiffs as Class representative;

(b) Equitable and injunctive relief enjoining FidoPharm Limited, Velcera, Inc. and

Wal-Mart Stores, Inc. from continuing to sell the product with its misrepresentations as to the risk

of the use of the product to the public because the product causes skin irritation and neurological

problems with greater severity and frequency than that cited in its misleading representations and

warranties in their marketing and advertising, that the Product "works the same way as Frontline"

which has been misrepresented as not entering the bloodstream and enjoining said parties to

undertake the injunctive remedies requested hereinabove;

23


(c) An order requiring disgorgement and/or imposing a constructive trust upon FidoPharm

Limited, Velcera, Inc. and Wal-Mart Stores, Inc. monies received from the sale of PetArmor and

PetArmor Plus products, and requiring defendant to pay Plaintiffs and all members of the Class for

any act or practice declared by this Court to be unlawful;

(d) Damages in an amount to be determined at trial;

(e) Statutory damages for violations of the applicable statutes and the Consumer Fraud

Acts. Pre-judgment and post judgment interest at the maximum rate allowable at law;

(f) Punitive damages in an amount to be determined at trial;

(g) The costs and disbursements incurred by Plaintiffs in connection with this action,

including reasonable attorneys' fees, expert fees and costs; and

(h) Such other and further relief as the Court deems just and proper.

DEMAND FOR JURY TRIAL

Plaintiffs hereby demand a trial by jury.

Dated: November 30, 2011 COHN LIFLAND PEARLMAN HERRMANN & KNOPF LLP

By: /s/Jeffrev W. Herrmann JEFFREY W. HERRMANN, ESQ. Park 80 Plaza West-One Saddle Brook, New Jersey 07663 Telephone (201) 845-9600

KANTROWITZ, GOLDHAMER & GRAIFMAN

By: is/Gary S. Graifman GARY S. GRAIFMAN, ESQ. 210 Summit Avenue Montvale, New Jersey 07645 Tel: (201) 391-7000 Fax:(201) 307-1086

24


GREEN & ASSOCIATES, LLC

By: /s/Michael S. Green MICHAEL S. GREEN, ESQ. 522 Route 18, P.O. Box 428 East Brunswick, New Jersey 08816 Telephone (732) 390-0480

DIAMOND LAW OFFICE, LLC

By: /s/Paul Diamond PAUL DIAMOND, ESQ. 1605 John Street, Suite 102 Fort Lee, New Jersey 07024 Tel: (201) 242-1110 Fax: (973) 302-8189

Attorneys for Plaintiffs

25

Case 2:11-cv-06976-WJM-MF Document 1-1 Filed 11/30/11 Page 1 of 2 PagelD: 26

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Pet Postcard

New Zei4ed2W/NlitigT6CWSIVFRONTiciNirrreV1 :-P -c'griled 11/30/11 Page 2 of 3 PAWL 'V

Log In

FRONTLINE Products I > FRONTLINE FAO > Dogs

FRONTLINE FAO

FRONTLINE* FAO

Pa and Tick Information

Ralanda Servir es

Since FRONTLINE® is so effective against fleas and ticks, is it gentle enough for my pet?

Why should I buy FRONTLINE instead of other treatments?

Should I re-apply FRONTLINE if I see more fleas on my pet soon after application?

Do I need to use FRONTLINE even if my dog is not scratching?

Can I stop treating during the cooler months when the fleas disappear?

FRONTLINE is absorbed into my dog's bloodstream Isn't it?

How young can dogs be treated?

Q. Since FRONTLINE® is so effective against fleas and ticks, is it gentle enough for my pet?

A. FRONTLINE has been extensively tested and shown to be well tolerated by dogs even at five times the recommended maximum rate on the label. FRONTLINE has been used with confidence on millions of cats, dogs, puppies and kittens worldwide.

Q. Why should I buy FRONTLINE instead of other treatments?

A. Long-lasting FRONTLINE provides complete protection from the biting stages of fleas and aids in the control of ticks in dogs. It is water fast, remaining effective even after repeated water immersion or shampooing.

Q. Should I re-apply FRONTLINE if I see more fleas on my pet soon after application?

A. No. FRONTLINE only needs to be applied every 8 weeks if using FRONTLINE Top Spot if FRONTLINE Spray. If you see fleas on your treated pet, these have most likely come from your pet's environment and will soon be killed by FRONTLINE.

Q. Do I need to use FRONTLINE even if my dog is not scratching?

A. Yes, not all dogs are sensitive to flea bites. Some dogs can harbour large numbers of fleas without being itchy. However as time goes on they are more likely to become sensitive.

http://frontlinemz.merial.com/faq/dogs/index.asp 10/25/2011

New Zeti48dgfai/Te&SWAIVRONNeigritsWf-RogFiled 11/30/11 Page 3 of 3 Pg8616:4i

Q. Can I stop treating during the cooler months when the fleas disappear?

A. This is a risky strategy. What is actually happening is that the immature pre-adult stage of the flea population go into hibernation. So, although you may not see them on your dog, they will be building up in the environment. Year-round treatment will prevent build-up.

Q. FRONTLINE is absorbed into my dog's bloodstream isn't it?

A. No. FRONTLINE is dispersed in the oil layer of the skin and then stored In the sebaceous glands of skin. Fleas are not required to suck blood to be killed.

Q. How young can dogs be treated?

A. FRONTLINE Spray can be used on puppies as young as 2 days of age. FRONTLINE Top Spot Is designed For dogs 10 weeks and older.

sack to Top •

® ©2011 MERIAL

Legal Notification Privacy Policy

http://frontlinemz.merial.com/faq/dogs/index.asp 10/25/2011


EXHIBIT D

Case 2:11

v-06976-WJM-MF Document 1-4 Filed 11/30/11 Page Tof 3 PagelD: 35

Case 2 1-cv-06976-WJM-MF Document 1-5 Filed 11/30/11 Page 1 of 2 PagelD: 37

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PetArmor Flea & Tick Protection For Dogs Up to 22 Pounds, 3-month supply

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PETARMORiell 3.11•111"121 I

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Item Description

PetArmor for Dogs up to 22 lb. provides the same #1 vete recommended active Ingredient, Flpronli, In the same concentration as Frontline. You get the same flea and tick protection as Frontline at a significant savings.

• Kills adult fleas, ticks and chewing lice

• Fast acting

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Online In Stock for:

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• Ship to Home

- This home free Item ships free with qualifying $45 order

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1

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EXHIBIT G

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PetArmor Flea & Tick Protection For Dogs Up to 22 Pounds, 3-month supply

(37 Customer Reviews) Write a review

3M NN1M

PaARMOKE REAS,1103,4 OWING UCE

Details Find In Store

Item Description

PetArmor for Dogs up to 22 lb. provides the same #1 vets recommended active Ingredient, Flpronil, In the same concentration as Frontline. You get the same flea and tick protection as Frontline at a significant savings.

• Kills adult fleas, ticks and chewing lice

• Fast acting

• Long lasting

• Waterproof

• Costs less

Online In Stock for:

$25.00

• Ship to Home

- This home free Item ships free with qualifying $45 order

http://www.walmart.com/catalogiquicklook.do?itemId=159921468ct=1319571956644 10/25/2011


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John Preston Mr John Michael P moon is Chal men d the Board of Dinoctors. Hs sened as a director*. Vekera since May 2004. From 1997 to 2000, Dr Preston was the rounding mmutwe chairman of morel, a lags amens haslet and poultry genetics company. From 1993 to 1997, he was President of Mord( AaVel and saved on the Management Committee of Merck b Co Inc From 1987 to 1991, Dr. Proem held woretecki reoponsitility ftr animal health product dm:Moment wIthn Merck. D. Preston Is also a Sonnet member of Ihe bawd of directors of Aare Mama Inc and Johnson & Johnson - Meek, Dr. Preston cinema his merinary dare from the University of Glasgow and a PhD from tne London School of Hyaline and Tropical Meddle. Dr. Preston is en honorary Professor in dui Deparimant or Clinical Studies at the University of Glasgow Vetwinary School.

Dennis Steadman Mr. Demu F Seethe) is Chef Execrugue deur, areCtor of Valcera Inc since May 2004 Prior to ening Valetta Mt Steadman founded Valorem Associates Ltd where he served as its Prudent, providing executive nrentigament and strategic Meson amines to animal Meth and Sated inclustnas. From its creation in 1997 until 2001, Mr. Sandman was with Menai, a rend hear company, wham ha held the positions of Vice Preadant Noel Mental Operations and Garet Management Comma'. Mamba with merial Ud. Mahal he led Me Successful integration of the veterinary businesses of Merck AgVat and Rhone Mutant iSanon-Avands) in elorM America From 1994 to 1997, Mr. Steadman ense Vice Presidait of U.S. Cperations for Merck Perot. and prior to which he wars respomlbe for Pectic Region Operafes Prior to joining Merck, Mr. Steadman was wIth Chase Econometrics (subentry of CMS° Manhattan Bank) for more then a decade conducting busineSs resat° and prnviding consulting services lo Ma awl-Maness sector. Mr. Seidman holds a Mater of Silence degree n AgrIculaire EconCinics from Pennsylvania Stem Unlveralty, a E.S. degree from PennsylveMa State University in Agnceiture Business Manage/mint. and tea competed an Emcees Program in Finance al me Harvard Pasonam School.

Matthew Hill Mr Matthew C. Ha Is Chief Financial Ceara since May 2007. Prlorto joining Voters. Ur. MCI was Chief Emanate army and Vice (modern or Operations of EP MedSyaterna Inc, a publicly-held madlcal device company from Mardi 2003 through May 2007. From 1994 through 2002 Mr. Hill hale mime mations. up to the lewd of after manager lath Grant Thornton LLP. the US. Iamb. len alter intonational accounting end auditing organization of Grant Thornton International. Mr. HS Made a sachem or Science degree from Lehigh Universty.

Nan ye math. ma Marva S. Defer is Drector of Versa sinesJuly 2007 Ms. Deahr ie Ms Child Legal Otter and Secretary of EUrand MV (NASDAQ' EURX)("Surinfl. Strand Is a speoletty charrractutice camera engaged in the dowslopmant. manufacture and commandelizalicn of mistimed pharmaceutical and biopharmaceutical products based on its proprietary drug formutatIon ectnologlos. From October 2003 b January 2007, M. Deals was a partner in the business and finance practice of Morgan Ltrab & Mares LIP. Mere she worked axemime; with Ile witness comment Pdort (sting Morgan Lewis, she was, among other things, Vice President, Corneal Counsel and Corporate Secretary for ton eery-stage trug Mooney company and a law dark for the Honorable Giles S. Rim on Me u.S. Cowl a Appeals forte Fran Orme She is arentrid to medics in Pannsywanis. Caltfornla, Colorado and tare the U.S. Patent and Trademark Office. the U S Supreme Court. and Me U.S. Coto of Appeals for de Federal Circuit Me. Deals heir a lee degree from the Unlace/1y of Wisconsin Law School and a bachelordegm in bicchamics sciences from Harvard Unhersie.

Joshua Karam Mr Joshua A Hamm is Bracer of Vetoers Inc Mice Sepamber 2004, he has been a partner In Two River Group. Hearne LLC, a New York based kertra °pie group bowed on creating new companies to In-license and davolou novel tischnologim From July 1999 to September 2004, Mr. Karam awned as a managing director at another venture Tao where he was responsiee for me operations of anon investments. Mr. Meant Is a erector of His Therapeutics MASDACI.NLTX) and Arno llerateutics (OCTIES:ARNI). Mr. Karam also Ciumealy senses as a director of several privately held cornamila Mr. Kann is a graduate of the VIMarlon School Of ens Ur:varsity of Prounsylvaria

Jerson Stein Dr. Jason Stan is Dirml or of Valuers lnc vino May 2004 Dr. Stein is amenity faunal, and ocohalrfrian of ACM Capital LLC and Actin Biomed LLC, each New York Surd halehare Investment Erna Previously, Dr. Stern served as Ma Skew Amiyst at fersocent gioCafese Asset Management MC. wham he ear reltoOneblo for medical, scientific, and financial rester° of pharmaceutical produce and tachneogin. since January 2000. Di Stain is also an officer or director of amaralother phoney hem revaloprneneataga boadmorogy companies Pe Slain received Ns undergradualli degree from the University of Mchigen and his medical degree tom Saba Unlovely.

Sal lailkatta Mr. Sal Lobate is Pinder of Velma Inc sinka Jur*111, 2006. Sinop Aquas ZOO, Mr. Ugialla has Saved as Ear-maw Vice Preokent, Haalthcare Practice Leader with SWAT Team Fanners LLC a redone orgarizatrin Mediating in strisegic business and marketing consulting From October 2009 through July 2007. Mr. Ugliette held the position of Senior Vice President Marketing. Saes and Hestracs for GaMY HR. an Mersey HR outsourcing and Medium beneltscomPany. PetWously. Mr. Ughtasi held numerous millions in the haalthcare Mild, including Head of Marketing al Mina and Prmidant of InteliHeadh, Inc.. a erten of Aetna petered with Ma Harvard Marital School, Vice President of Marketing end Seas of Johnson lJohnson-Meck Joint Venom, and Eteopean OTC Badness Heed at Johnsen & Minson. Mr. Wade news a BS degreeIran Brandin* university are en MBA in Mtakaong Ind Intanueonel Bu singes from Cokenbie University. He to a highly regarded healthcare asectiere Mass 30-yeer career ancompassee raccassel domestic and inernational growth.

Harold Tuber Mr. tiered L. Suter la cannier of Valera sine July 2007. Mr. Sober is outmode cmgagsam entrepremunal 'Manse with • number of erect minority asestrants in companies Wage "MUG industries From 1990 to 2003 he wee alai Financial 011berotTelefion Incorporated (NYSE:TFX), a evarelled IrAussigl cangeny specializing In the Assign. rniengaciere end clIssibutIon of initiate-angKeemes products serving me commercesI, sernspaces and Medical iMustles. Mr, Zuber °met) semis an the board of directorsof a ;Maw medical device Startup company and of a private electronics distributor Mr. Lear has also served on boards of two pubic companies, a medical etellizeion service, company and a mortgage real estate immanent trust foratich ha alto served es CJISITIO/1 of the audit cominerm It. Zubb molds a degree In Business...7101,01am from Clarion Sties Cane and is a member of to American Magma of Califrod Public ACCOU/11811th.

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EXHIBIT K

June 24, sone MN welcome to Medal 115

For Pet Owners

For None Owners

For Lbw:stock Producers

For Veterinarians

For Chaired Partners

For Licensing Partners

For 3eurnallets

Man Select Species

Select a Product

umormaarc: Select Species Select species

Select a healthcare Solution 111 Select a service ■

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A World-Leading Animal Health Company

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MANUFACTURRIG Manufacturing for Mena/ is a global operation with 16 manufacturing sites around the world where the company's products for livestock, companion animals (pets) and wildlife we produced. Merial'S manufacturing capability falls Mto two main categories - Pilarmaceuddes end vaccines. Manufacturing's responsibilities Include sourcing the company's leading products including the ivermectin and ?}prong ranges, with such well-known brands as IVOMECO (ivermecdn), HEARTGARDO (tvermectin), FRONIIINE6 and FRONTLINE Plus.

As a leading global company, Menai Is committed to the highest international standards of product quality and safety at Its manufacbaing *es world-wide. This means compliance with standards and cooperative relent:tripe with regWatory authorities In the markets where we operate. At every stage of the production Process, we Insist on stringent adherence to processes and Procedures for health, safety and environmental protection, quality control, quality assurance and regulatory compiance.

Each year, Merial produces 100 million vials of vacdnes which equate to 300 million doses for swine. ruminants, cats and dogs and 50 billion doses for birds. Menal also manufactures 100 million pipettes of FRONTUffEd • the world's leading tin and tick treatment for cats and dogs, and 300 million doses of IVOMECO (Ivermectin) andparaskic treatments for ruminants and swine. With our comprehensive manufacturing network, Merle is able to make products for our custorners In all mayor animal heakh care markets, providing local expertise bided by global economies of scale. Menal's current manufacturing activities are concentrated In Europe and the Americas. European sites Include four In France (three In and around Lyon and one in Toulouse), two In Italy (Novarta and Chignoto-Po for avian vacdnes), and one In the United Kingdom (Piroright for foot-and-mouth disease vaccines). In North America, we operate five sites (Including vaccine production In Athens and Gainesville, GA), while we conduct additional vaccine manufacturing at two sites In South America (Padilla, Brazil and Montevideo, Uruguay). In Pauline, Brazil, a new facility for the production of invermectin fonnulabons was Inaugurated In 2004. In China, we have one Ste (Nanchang); we take also part In a ISM venture (Narding)•

A large number of spedallsts globdy ensure that the company meets both technical and regulatory requirements. The operation is supported by more than 1,700, bidding chemists, biologists, Pharmacies, veterinarians, quality control and assurance technicians, engineers, logistics end production Waft

Our commitment to our customers is to provide the best quality Products on time, at optimum costs, and where they need them.

02009 Merit Legal Medication Privacy Policy

http://us.merial.com/around world/martufacturinstfutdex.aso fintinOno


EXHIBIT L

Case 2:11-cv-06976-WJM-MF Document 1-12 Filed 11/30/11 Page 2 of 4 PagelD: 61 Saaltraf as 41*-•IMPI vne zartAMIIMI nal* mot nil I MIS I la kVA rei lin

ittowisignmett Peso:tries: tiesthltar

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Ittcnimmul Scrutiny of Rend Tick Centrel Pasta fur Pets Data e recent sharp inane in the number tinekients Oak* repo** ham the use or spat-oat jamilefde inducts far Net ettil litshadetnialbr em:OrsAMentvoitad MAMA AIM* *PA) kr kadheTTYing ItitowlMat Oftlitiethardirther metticharecen me we of this predecitese neinaliaryte totteroment pab.

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EPA-mgistenerd spobam, teektellli **Med No *MI itok Pedant, fun 1111 .elPR itatiWnek. MSc cm the label (leek for EPA Reg, Net mossici.

buidowit sport swanway Maas read** rigistad from the spat-ea dide. titan altatatadnittildlt ifilketkitle•Madialigelle tikdis dash native rl tt settiatiaMadoeilt. Ober 4000

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• Thls -. s SOW to retedits lettie* iiathetee • Thbk Wirdriten 0:41$ tat ► SW* fdtflee limitartilstetta podia* • 11* kehntedien dem net reRect, *a wig d kg el Widgets; • Mfg Itteratoden Nape net refit* ~it Mbelle -tdtha Ormiladit* • if ind11000 etas net repiwtOd by pet MOS er figlatrentsi Min. way

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Case 2:11-cv-06976-WJM-MF Document 1-12 Filed 11/30/11 Page 3 of 4 PagelD: 62 • a.. tan • Pea 10.0V•IN %.• • •eWitid• LP. / coiwsuc I LAP Ora CISP h til 3

agreement with the primary registrant. EPA requires that the label for the distributor ProdUCt be Identical to that of the primary product (In terms of uses of the product, precautions, etc.). Distributor products can be identified by having a three-part EPA registration number instead of a two-part number.

EPA Ragistration Number

80490-2

0 65331-5

125 65331.4

2724-504 or 2724-504-270 or 2724-504-2596

2724-497 or 2724497.270

Product Names

Pzerammis Spot On for Dogs Promerls for Dogs

FariallRia Sas for blip

PtimOlne Plies for •Cols

RP2004(CCSO) Zodiac "'pet On Flea &Tick Control for Cats 5 lbs and over Zodiac Spot On Flea & Tick Control for Cats & Kittens Under 5 lb. Farnam Companies Inc. , Spot on Flea & Tick Control for Cats & Kittens Under Sibs

Co ' for

Inc. Adams Spot on Rea &Tick Co' I for Cats Sibs & Over Famam Companies Inc. 1310 Spot, Spot on Moo & Tick Control for Cats SIbs & Over The Hartz Mountain Group Hartz Ultraguard Plus Drops for Cats The Hartz Mountain Group Hartz inoontrol Flea & Tick Drops for Cats The Hartz Mountain Group Hartz Ultraguard Pro flea & Tick Drops for Cats The Hartz mountain Group Hartz Incontrol Advanced Flea Si lick Control for Cats Sibs & Over The Hartz Mountain Group Hartz Incontrol Advanced Flea & Tick Control for Cats

RF9905-lisat on Zodiac Groomers' Spot On Pack Zodiac Spot On Rea & Tick Control for Small Dogs 16-

Zodiac Spot On Flee & Tick Control for Medium Dogs 31-60 Its Zodiac Spot On Flee & Tick Control for Large Dogs Over 60 Its Zodiac Spot On Flea & Tick Control for Puppies, Toys & Miniatures under 15 lbs Farnam Companies Inc. Blo Spot Spot on Flea & Tick Control for Dogs Farnam Companies Inc. Companies Inc. Bio Spot Spot on Flea & Tick Control for Dogs (16 to 30 Its) Fernam Companies Inc. Companies Inc. 510 Spot Spot on Flea & Tick Control for Dogs (31 to 60 lbs) Farnam Companies Inc. Companies Inc. 810 Spot Spot on Flea & Tick Control for Doge (over 60 lbs) Farnam Companies Inc. Adams Spot on Plea & Tick Control for Small Dogs 16-30 lbs. Famam Companies Inc. Adams Spot an Flea & Tick Control for Medium Dogs 31-60 lbs.

hitt.. /Ammo one easseiwasne4.6.11....1.1./A.... • In • 00.0•01 n

Case 2:11-cv-06976-WJM-MF Document 1-12 Filed 11/30/11 Page 4 of 4 PagelD: 63 mime • awn 164•144•4 VI 4 4~1441.0 ISM rue I rtataauva I uG Drat rage s Oi J

(i) 2517-85

Fornam Companies Inc. Adams Spot on Flea & Tick Control for Large Dogs Over 60 lbs. Femur, Companies Inc. Adams Spot on Rea & Tick Control for Puppies, Toys, & Miniatures under 15 lbs Farnam Companies Inc. Bio Spot Spot on Flea & Tick Control for Puppies Under 15 lbs

iiiimilsorilCyphenothrin Squeeze-on for Dogs Sergeant's Silver Flea and Tick Squeeze-on for Dogs MON XPC

Squ Flee

eand a T

-on fick

or Dogs Squeeze-on for Dogs

Sentry "VC ze Sergeant's Silver Squeeze-on for Dogs

2517-80 Seigemaata Cyphenothrin IGFt Squeeze-on for Dogs

el or Sergeant's Gold Squeeze-on for Dogs 2517-80-83333 Sergeants Gold Flea and Tick Squeeze-on for Dogs

Sentrypro XFC Flee and Tick Squeeze-on for Dogs Sentrypro XFC Squeeze-on for Dogs Sentrypro XFC Rea and Tick Squeeze-on for Dogs Extreme Flea Control Tradewinds Triforce Canine Squeeze-On Tradewinds Trlforce Canine Squeeze-On for Dogs 9 Ms to 20 lbs. Tradewinds Trlforce Canine Squeeze-On for Dogs 21 lbs to 39 lbs. Tradevrinds Triforce Canine Squeeze-On for Dogs 40 lbs to 60 lbs Tradewinds TrIforce Canine Squeeze-On for Dogs 60 lbs. or larger.

Regulator, agencies are taking action

Health Canada has Identified similar concerns about the use of spot-on flea and tick products. Health Canada and EPA will be meeting with product manufacturers shortly to address this Issue, Including whether further restrictions are necessary to protect the health of pa

WM.//wane Ana tenishiath:n:AabolLastelaa".. 44,


EXHIBIT M

trari. a. r‘sCanmtEmlitasm-009804ftfrA-INIRtulatnartmeakitaiffigeNdkfitIVA1018 ftsigetZcodd PagelDifle 1 or 3

PE Store Locator Order Stake

Store trails Register

Your Account

Quick Reorder

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.11"socuor wow Wpm

Dog Supplies Dog Food Cat Supplies Cat Food Fish Supobs Live Fish & Rock Natural Foots PETCO Coupons

Small Animal Supplies Reptile & Amphibian Supplies Bird Supplies Wild Bird Supplies Specialty Blom Stores & Events

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Cold Weather, Hot Prices 4-Day Sale * FREE Shipping on $60 Thousonda of items on Soh — Ends 01/18/10 - 1 Mestrintiont apply.; Get Promotion Cods

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Food Brand Center

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1111111* 1111111. The EPA has reported en Increase In complaints about adverse reactions lo spot-on flea & tick products. The health and

well-being of pets is our top Monty, so please mike sure to reed end follow ail label directions caret* end watch your

pet when using any kind of medicine or supplement. We encourage pet parents to consult with their vet when using over

the counter medicines.

Increased SA:MtillY of Flee and Tick Control Products for Pets

Source: www.epa.gov

You are term Flea & Tick Om

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ittn•llonarol notnn newnInatre. Ticirra Di' ImPratne.41 44 Men. QiCn 'KT 111 ... --Jon sr 01_ _ _ 01 • • nn.rna•e.


EXHIBIT N


PETARMOIT FOR IMMEDIATE RELEASE

CONTACT: Linda Yun

lyunpwebershandwick.com

312-988-2320

Nicole Lowe

nlowe@ webers handwi ck.com

212-537-8747

FIDOPHARM AND THE ASPCA TEAM UP TO LAUNCH NEW PETARMORTM OVER-THE-COUNTER FLEA AND TICK TREATMENT

Generic Version of Frontline Offers Increased Accessibility and Affordability to Pet Owners, Collaboration Rallies Nationwide Support for Better Health for All Pets

Yardley, Pa. (April 20, 2011) — Actress and singer Mandy Moore joined FidoPharm today to introduce

PetArmorTM, the first generic fipronil product available on retail shelves nationwide with the same active

ingredients as Frontline To celebrate the launch, Moore, FidoPharm and the ASPCA (American

Society for the Prevention of Cruelty to Animals') have teamed up for a national awareness campaign to

highlight the importance of flea and tick treatments and other preventative pet healthcare,

Moore joined the campaign to launch PetArmor and encourage pet owners across the country to take

the PetArmor Protection Pledge in support of the ASPCA, a leading animal welfare organization. The pledge underscores how products like PetArmor provide greater consumer access to affordable quality

care, ensuring better health for all pets. Consumers can purchase PetArmor over the counter at

significant savings.

"Together with Mandy Moore and the ASPCA, we are excited this campaign brings to life our promise of

better health for all pets," said FidoPharm President Alex Kaufman. "With PetArmor now available over

the counter at local retailers, pet owners will have access to the highest quality flea and tick treatment

at a price they can afford."

Take the Pledge The PetArmor Protection Pledge aims to create a community committed to better pet health.

FidoPharm will donate $1 (up to $100,000 total) to the ASPCA for each pledge taken on the PetArmor

Facebook page (www.facebook.com/PetArmor) . Every person who pledges also receives a $2 coupon

toward a purchase of PetArmor.

"As a dog lover and someone who takes pet health very seriously, I was happy to take the PetArmor

Protection Pledge and use PetArmor on my dogs to keep them safe from flea and ticks," said Moore. "I encourage pet owners from coast to coast to make this promise and give back to the pets that bring so

much joy to our families."

-more-


An Official Flea and Tick Treatment

Having selected PetArmor as an official flea and tick treatment, the ASPCA will use PetArmor for dogs and cats at its adoption center and clinic. Pets adopted from the ASPCA through the end of the year—

including animals recovered from RSPCA disaster relief and animal rescue efforts — will also be offered

PetArmor.

"Because the ASPCA and FidoPharm share a common vision that all pets deserve the best care, it was an

easy choice to make PetArmor an official flea and tick sponsor," said Elysia Howard, vice president of

marketing & licensing for the ASPCA. "With the support of PetArmor, we rest assured that needy dogs

and cats will receive the effective flea and tick protection they need to live healthy, happy lives."

In addition to providing free treatment, FidoPharm is donating up to $100,000 through the PetArmor

Protection Pledge to support the ASPCA's efforts,

Coast-to-Coast Protection PetArmor contains fipronil, the same No. 1 vet-recommended active ingredient for combating fleas and

ticks, in the same concentration, providing the same flea and tick protection as Frontline. It is the first generic fipronil product approved by the U.S. Environmental Protection Agency to treat both cats and

dogs of all sizes, and comes in two products: • PetArmor (containing fipronil) — kills fleas, ticks and chewing lice • PetArmor Plus (containing fipronil and (S)-methoprene) — kills fleas, flea eggs, ticks and chewing

lice

PetArmor is the first generic fipronil flea and tick treatment available on retail shelves nationwide. For

more information about the product or to take the PetArmor Protection Pledge, visit www.PetArmor.com or www.facebook.comPetArmon

About FidoPharm

FidoPharm is a leading pet health products company committed to providing consumers the most

affordable and effective alternative medications to veterinarian-recommended brands. FidoPharm

products are available at major retailers nationwide, offering consumers the benefits of convenience

and cost savings to ensure the highest quality care for their pets. Learn more at www.PetArmorcom.

About the ASPCA Founded in 1866, the ASPCA" (The American Society for the Prevention of Cruelty to Animals') is the

first humane organization established in the Americas and serves as the nation's leading voice for animal

welfare. One million supporters strong, the ASPCA's mission is to provide effective means for the prevention of cruelty to animals throughout the United States. As a 501(c)(3) not-for-profit corporation,

the ASPCA is a national leader in the areas of anti-cruelty, community outreach and animal health

services. The ASPCA, which is headquartered in New York City, offers a wide range of programs,

including a mobile clinic outreach initiative, Its own humane law enforcement team, and a groundbreaking veterinary forensics team and mobile animal CSI unit. For more information, please visit

www.aspca.org. To become a fan of the ASPCA on Facebook, go to htto://www.facebook.com/aspca . To

follow the ASPCA on Twitter, go to htt : www.t ias ca.

Frontline is the registered trademark of Merial. Frontline and Merial are not affiliated with PetArmor.

SUM

PetATtige-24-8413:1139W3dVVJM-MF Document 1-14 Filed 11/30/11 Page 4 of 5 PRWlictfg

Ettlt* Iw ri 0 a SHRRE

Why PetArmnr Prndurt Ender Healthy Pets Pet Pleynitund Media

SIGN UP. JOIN IN. AND RAISE A PAW TO HELP PETS.

PET PLATGROUI43

WHAT'S NEW ASPCA ALLIANCE

Mandy Moore rallies pet owners to take the PetArmor Protection Pledge to help support the ASPCA

MATS NEW?

ASPCA St.Ffter

The ASPCA proudly uses PetArmor in its adoption center and clinics,

Read MOT

Join the PetArmor Protection Pledge. In exchange, well pledge to donate $1 per person to the ASPCA to help pets in need, up to $100,000. Click below to watch Mandy Moore at the April 20, 2011 PetArrnor launch.

To ensure better health for all pets.

To make our products affordable to pet parents. With PetArmor, we provide the same flea and tick protection as Frontline Top Spots, but at about half the cost."

To protect pets with PetArmor and by encouraging regular trips to the veterinarian. And through the ASPCA, one of the leading animal welfare organizations.

'comparison based email cutlets

To protect your pet from fleas and ticks and to help your pet live a healthy, happy life.

To take your pet to your veterinarian for a routine spring wellness check.

To proudly sign the PetArmor Pet Protection Pledge for better health for all pets.

Tatce the, •leine

http://www.petarmor.com/playground/whats-new.php 9/19/2011

PetAogge-2:lielt-VAD1391313ANJM-MF Document 1-14 Filed 11/30/11 Page 5 of 5 Pllgita[3:106

Signing up with PetArrnor.cOm IPYLL PETAAMOR PRODUCTS PET HEALTH INFO

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9/19/2011


EXHIBIT 0

Anima/aka/41 colttar697i84/MtaltiMiornffigt4 :1-4f,PCSiRial$130/41 Page 2 of 7 P130140:012

ASPCA Professional

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APCC Consulting Services

The APCC provides veterinary toxicology consulting to veterinarians, pet owners, and clients in pharmaceutical, chemical, home-product, and animal-product companies on a wide array of subjects, including:

• legal cases • formulation issues • product liability • regulatory reporting • biosurveillance

Services the APCC Offers

Overview of APCC Consulting ServicQa Get the big picture of the APCC's many capabilities as veterinary toxicology consultants.

Prod The ASPCAAPSS provides leading edge, customized solutions that support our clients' product stewardship.

Industry and Government Consulting The APCC can provide confidential veterinary toxicology expertise to meet special project or legal needs of both private and public organizations.

Agriculture Consulting The APCC can provide treatment and diagnostic information for livestock exposed to hazardous substances.

biosurveillance and Terrorism Affecting Animals Unique biosurveillance capabilities can provide veterinarians and state government and health agencies with the ability to report any suspicious nuclear, biological or chemical incidents involving food animals, companion animals, and wildlife.

http://www.aspcapro.org/apcc-consulting-services.PhP 7/12/2011

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ASPCA Professional

You Are Here: 13g= > Animal Poison Control > APCC Consultinv,Services


ASPCA Animal Product Safety Service

The ASPCA Animal Product Safety Service (APSS) leads the way in providing customized solutions that support our clients' product stewardship.

The pillars of the Animal Product Safety Service are our incomparable staff and advanced information systems. Our veterinary experts share more than 125 years of combined poison control center experience and more than 75 years of combined general toxicology, clinical, and diagnostic experience.

Our Animal Product Safety Service (APSS) division provides services to corporations. We manage adverse event cases and provide extensive veterinary toxicology consulting on legal cases, formulation issues, product liability, regulatory reporting, and biosurveillance. We assist industry through technical support, pharmacovigilance, and related services.

Features

• Incomparable veterinary and toxicology expertise • Advanced information and reporting technology • Unsurpassed credibility

Advantages

• 24/7 immediate call response • Detailed incidence data • Medical expertise key to differentiate product reaction from disease condition

Additional Services

• Technical Support Services • Field investigations • Special reporting • Consulting Services

http://www.aspcapro.org/animal-product-safety-service.php 9/20/2011

AnimGictisko cAuttro6051WANairna1ilintivat fitifts3tSentioed AMAI troft4onabf 7 Feg#1 04

• Completion of FDA 1932 forms • Completion of PMRA incident forms and annual reporting • Human call management through our partner

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You Are Here: Home > Animal Poison Control > APCc&onallingSgaicgs


Industry and Government Consulting Services

The AnToe.' Veterinary Toxicology Consulting program provides confidential toxicology expertise to meet your special project or legal needs. Our staff includes veterinary toxicologists who are certified by the American Board of Veterinary Toxicology and the American Board of Toxicology. We have provided services to industry, governmental agencies, toxicologists and veterinarians.

Examples of confidential expert consulting projects include:

• Special reports based on our AnToe case database, which contains over one million animal product/substance exposures collected by the ASPCA Animal Poison Control Center

• Review and publication of our poison control data on specific products or active ingredients • Expert field investigations or facility inspections • Development of treatment protocols designed to manage animal exposures to specific products and

compounds • Extensive product safety assessments on both new and existing formulations • Management of clinical trials in support of FDA NADA • Legal support and expert opinions

Our clients have included both industry and government organizations. For example, the APCC has worked with the Food and Drug Administration and the Environmental Protection Agency, providing them with animal incident reports on antimicrobials, non-steroidal anti-inflammatory drugs, and pesticides.

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Subscribe i Do It Today! ASPCA Webinar Series Shelter Eacua

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RSPCA's Dr. Steven R. Hansen Named Veterinarian of the Year

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February 01,2008

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the aid us ceremony was held on iconicity 9, 2608 at die OrenS Hyal. Hotel in kev. Yet City

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norn sreconigoiy Opagnoche corcerate and (i).1tabOratones, was inter prefect fen tee LAMM on an

ongoing basis. This consratent new Or rehab). information, along wall the resultant

reCommenda tram guided the largo< or pet parenc nationwide warning countless. ices in the

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1. along vote, me entire orgarzatlon. am very prou0 of Misr recognition or Dr . lla. wen's !eaderShin

during eclat year; unpreCedented pet food recart CtiSia," said ASACA Crewe-en, A CEO Ed Sayre,

ric, "'arose ante remoter:press combined with our oommuncations expectWe wen the wren

our organriated was able to help the American p.plolic and their trees ope from day Lo day. -

4 dd.:1:9191 roncrees included Cesar Milan for Tra.9.er of the Year, the staff of the Irvine Armlet Can:

Center Shelter of the Year. and Weeaershanow Wender Sanitises who war, fildrifued int° the Anne Pogers Clerk Mall or Fame

nr uensan w teenchcertified by the American Goats of tog.sology and Me Arneficati Boon, m

veterinary Toxicology, holds an adjungl avow/titmice. at The University or Hines College or

Waterman, Medirilo ent, serves on coteries y give -mow-1W and cot pn-ain r919 , SOW tOmmittoes

'9 ,1 9Crered to receive coon meaningful !cognition, solid Lt. Harman. "Howeacr, the ASW - A s

rerfrowse tc trio inti. croft Retail ,1,1;9!. wan an extrenelv Cr9atCrat, foro trod !snare rum aware

A.. n all nip catermaes The combined efforts or our peso& mechcat and oommun'ca'sces team!, as

AO as veterinary thar]coStra, qtrherrwreitil and Corperble labOratortei positioned or. syWi to

terra Ince and oelwer meaningful recomme trait reass Jen pot parents-and s ulna, nrudn

I:aDoleio 9 is, the ASPCA 990141Proaor. Control Centric is ine 0.19/ 24-hohr 26. la, faciley

T kind stalled by 30 sagerThaitans Including 12 79.1rd C9rt..led tornturnowthmeterinary

taKeologirits and 13 Certified veterinary li9C19-,99A,19. Located at the ASPIA's Midwest Otte m

Urbana, !h i trio specrallf bane Staff pi made: assistance to pet Owner, and ctieofic diagalOStrc

atm ft-eat-mar& recominendaterw to vetnonarrant Pallz,ning to toot themicara and dartgeions

pianos , &tierce or auto:Antes to 2007, Vie Cenlia• bandied Over t 30,00e Cases. The ct Mc! also

ocardn,tenswor veterinary toxicology expert rensuitmc on n node array or stblects Cl inadss0 kecial Case

ex

s. firnihrat!on Niue& product hability, and regolatory mount,ng

wounded .21 1866, the ASPCA S rr he American Society for me Prevention or Cruelty to AMMaIS p£

to first hi Mane or ganizahon eatabhaned rn the AillelCitS arid acmes -Jrr the nation re leading voice

foranima , werfa re . One inn ion su Oponere strong, trie ASACA's rririS1011 -0 Co oroWde effective

ea-,9 for the Dreveatp9r, Cr ca,elty 1,3 amman [01 -<9,99Ut lire &Throw State, As a SDI [0] 131 nut-

:or-or:slit carporarin , , the ASI3 CA is a natiOnal peaoe, i n the areas of anti ..cruelty, commt,n,tv

cotseach and arirmai health cervices. The RSPCA, White i5 heateartered how, soon Cloy, offers A

,arifje of pro-dorms, ,r1C;ading 09199,1e Clinic wAreanti milatice. WY .990 rwr9999 law

enrOrCaMent ream„yrd e 2-0uraldreekasil votersiars foreharcs team arc mope anima! Cs( mitt

err mare into - rnauon, please. visit www osch.a urn,

become alai! or Use ASP ,-LA on Factious no DIU:DN. 10 follow the

COCOA ee Twitter, 00 t0 ht•• 929994 Lw, ,e1 rTINVA 9oc ,,

0

http://www.aspca.org/pressroom/press-releases/021108.aspx 9/19/2011


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EXHIBIT P


■APAIVLASPC:A.C.•;RG .4J

FOUNDATION AND CORPORATE SUPPORT . We deeply appreciate the growing group of institutional donors who make significant grants each year. Their generosity and commitment enable us to advance our programs and improve the lives of animals across the country.

'.Hy 4,, ,

Resin Bane Frankenberg Fourdokan The Leono M. and Harry B. Helms ley

Charitable bud

Bloomberg Grousbest Family Foundation The max NI. and Lre Kohn Memorial

Phlanihropic Fund The New York Commonly Trust

itty 00 ? Manymaus (3) Alga Untied Way / Molding GAI hog mm Bonk of Muria Foundation Fogre-Com Fmogene Goble Fund 01 The

Galgornia Community Muni/than tkadde's Fund The National Horse Show The Margaret This Fret Foundation Sumner M. Redstone

Chadds* Foundahon Me William and Greno

Bfiresslein Foundolion Wirepoirk Foundation ZBI Employee Madded GM Fund

3 ' 3010 I Bat ?0 9

Anonymous (2) The AmbHola Company, Ina maks Chemical Gordo/MS

in Memory at Fenia Caller knhoia Foundation. Tic. TM Sandal Mos Boss and EON

and Sal G. Mos Fund. Inc. The Brown Foundation, Inc. award Boutique Jonice M. Clarke Dr the Fidelity

Credrade GO Fund Firemen M. D'Abostina

Foundation Comoraiian Odl tired Giving Condon The Carnes Engelhcrd Foundation Roger S. Monona Foundation FAN Opinions Global Impost Greg& The/ono Foundation. It The John S. all James L. Kright

Foundation me Hermon Ussner Feundarton. Inc. Bill and Joy McGinnis Fund ham F. Magill Carbone Trust

Notional Foundation. Inc. Peed Media Pfizer Foundation Matchirm

GM Program PLM Sands Belle Moe Chariton hind May and Sorniel Rodin Fanny

Sionorren Inc tae Pelee Joy Sharp Faundoton Judi and Sward Strauss Foundcban Tidiest Philantroopy True Religion Brand leans Vonh For Wacroria Foundation The Shaw and dew Water

Foundation

Wells forgo Corartnitv Sumat Campann

The Westmlnstet Kennel Cub

Amery/now 1STOI8S.00M. NC. Aldred Laboratories Ablate Giving Campaign Amgen Faurelatian The At Founda lion, Inc. Me Mantic Figlantretpies Director/

EmdOnle DeSignalect GC Fund Babbitt Family Ghodtable Foundakon The Mitchel and Kathryn Boren

Forney Sandals Jock and Nancy Brementhot

Fanny Fund The Elmer and Man isa°

3otiot Foundation Jean M. Cooney Chorea* Fund

al the American GM Fund Cardinal Health Founitalion Chson EmplOyee Ching Campaign Clovis Fontlalion, Ina Crenshaw Carpordlon nolo Family Foundation. Inc.

The &Sara Dorsch Foundation Duval & Stochenlere LIP Edg The Ed000rd Montnan. Ina. The EMJUS Faundafion !be Frankel Foundation The Fuchsberg Family Founiofion GE Foundation Lawrence M. Gelb Faunddin MC. The malcakn Gibbs Foundation, inc. Goldman. Sachs & Ca.

— The Holz Mountain Corporation -- Josephine Lawrence Hopkins

Founds:inn

Iwo Foundation For Education. ErwiranmeM & The his

Johnson & /Olson EmoreYee Fund & Mulching Gills Fund

Rathnein Kass Foundation. Inc. The Kinnaull Feu-Potion The larks:lick Family Fund lash Rundaton M9 Charitable Fund

Maverick Col:0 Munddian McGrew-Hill Companies lAerrill Lynda &Murder MGM Mirage Voice En/natation Mobile Ching Fourreahrin Neue Gore he Henry Nina Foundation. Mc. Pearsonnappaprt Mondale:in Peireglyah MASON Seivids Progressive Insurance Foundation Palms Rose UP Join J. and Inez K. Ross eh/edible

fund of the Central Carolina Commonly Foundation

Samowitz Foundolion Strauss Founds Choke and Mildred Schnumnocher

FoundallOn. Ina The Shuben Digo Nation. Inc The Stephen A SIgeOrile Family Sire

Toby Stan True

The Stringer Mondani Swanson MAIM Giti Fund -

Jane L. Swanson

Topney Ms Family Fund DI The Saone FoUndallon

Tax, Inc.

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George Wassermon Family Foundolion.

Young Woo &Alsocidel LLC

9;03 gay

Ananwnaus ( 1 3) I St fintuialBD te 4 Chan& Founzialian, Inc. Aaron & Marian Guar! Foundation Ace Inn Foundation Adam Gballogatnyay foundertan kreurY Giou♦. LLC /CT, Inc. rye Ages Family Foundinor Mahe Syslems Isar/naiad Anna Foundation MG Matching Gronis Prngreell Mean S. Wow Foundation Me Groin Mx, Panty bust eked end Winds Ebert Fanny Tout

Ahmed Lobs Men FamilyCharilohle Fund Al-Mobile Boil Bands knerrean Cannuclion Company Amevican Fatness FounOalion Amerimor Enlereases, Inc. Arnerioase Grioncid Services Arnica Cowponies Foundation Maslasia Charitable Foto:San MMus Fanny Find Milo B. and Howard S. Richmond Foupliglan Inc. MING Incomaided Arthur J. Gallagher Foundation Associated Budding Sup* The Assaciokon DO Happiness

Far All Molar& (PIAM)

AST Coplal Trod COmconY CUM:more

Astoria Feded Savings AskoZtireco Phirrroteukcch LP

PAC Matti Program Murian Mantic Mani Services Marsh DS Processing. Inc Molar inieslmend. LP Avon Products Foundation Ara Foundation The /woo Chant* Foundation Ballad & Drawn Bed Ideas CC Bogey Banks all Biddle Benkeld Chartable Trust Foundation Bork Dl America

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Cons/nil/ Payment Bonk aline %reel The Baobab Fund Barnard and Minaret Fink Monde/cm Becton Dickinson & Company Begonia Ho and Jim Dineen Fund Benerends, Berms Be Barbara and JoSegh Lee Fund Bernice sod Edward NArnats

Philanthredre Fund BEIM Pet &direr Inc Bernard/fart Ina Big Y FOXIS. BM & Melinda Gales Foundation

arts Wads Foundation Black &Decker Bloantekg Matching Gills Program

Area Men Hannan BP Fob* at Americo Fund SR Fantation, Inc. BPJ Holding Corporation

Bradley L. Golsterg Chadable Trust gagman Nyman Galardi LTC Brake-Fast, Inc. Grandes Brothers Consist°

Brodie/1 kitleftetiOn The Breakers

&tip! Mohr Speedway reistol-Myem Squibb Company The Broodlidge Foundalon WookwodIComponies Indorporeled Bruce G. and May A. Robed

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holders Fautornerd and Sup* Bungolois Community Art Priced Boding Management Group

& WConsMiclion, Inc.

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Community Foundation Cenral Group The QOM @WO Canines Gare.Cont Ina Can Sommer GSM'S fund Carl Jacobs Foundation Cads/ Faundaran Carolyn Curter Skin Foundation The Corson Family Foundation. inc. Cerritos Ford bid Charitable Non Fund Charles & Lucille King

Family Foundation Charles & Sue Schad Of Hair Choges Schwab Commas

Foundation Charles Stewart Molt Foundation Chagane Woodson/cliques CHART1S

The GSrlY Picker FOundatan Grubb Federal Insizance Company Cisco Systems, Inc. Ciltnoup Faun/isms Citizens Bont Cilia S. LW Trust Clement and Karen /bison Fanny

Charitable Faundalkin Cos Company Foundotion CME MM. Inc. CAE federal Credit Union Cash Cole Son COW Mgr:Omens, MC Carman Comormion Commercial Microwave

Technology, Inc. Comoc Inc Computer Associons Corwin, Gig Chonlahle Trust Conn and KM Coviciten Crocodile &flees Children's De retstry GRIAM. Fund OalicN-honkyo

Dancing Tides Foundolion Don's Charily Fund Data Works

Dond Allmon Foundation David and Ellen Petrick Sanitarian

the Dowd and Sandra Mack Fairly FoUnclailix

Dayton Foundation Depository, The Ce Bachmann Family FauMolim The Deane A. and John D.

053rn Foundation Delta Western. Inc. Morel Family Fund Deutsche Bank Memos Foundalion

Discover Financid Services Disney Wortande Outreach VoluntEARS Disney Worldwide Services, Inc. Dominion Mongolian

Danna and Levinson Prganthropre Fund

Doug Foris Chorilable Fund Wean Smiles Dental P.C. Ca Scharr & Lome, LLP Dun & Banshee' Caporation

Foundation Duro Dyne NolionolCard, ['Trade Financial Corporation E. Raymond Asteby Schad EA. foundation dray Foundation ECDNDLITE Edelson Foundation, Inc. Edison Inlemorrond Educational Testing Service Edward ArierwrIsch Foundation Eel Pinar Fund El Paso 0(am:catkin Eledronic Ms Malang Gifts Program Elizabeth and Andrew Word

Month* Fund Elizobelh V, Becker Trust Eliot & Constance Estes Foundation The Emily Hall Tremoine

Foindation. Inc. Empees Charity Droontraren Dt

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Employees Community Fund DI Me Boeing Company

Friona Di and Cos.Inc.

Energy Far Others (mach Cord Erns( & Young, UP EuonMahil Foundation Moulton-a Resources, Inc Fonind Liadlarne High School Fannie Moe /arida:ion Fanny &Stiffen Rasenak Faindation Ras &Egad Press Mated Fund

Fein Foundation Fiduciary Misr Campony International FIrs1 Drip Corporation Ara Pee it Adele= LLC Assigning. no haste Pohl Feeley RIM Reel Tidier Leasing. LLC Wisp SOMojo. Inc. ford Fardation Bannon Family Foundation honk, Rise/sin & Co. LAP Freda FamiN Foundation Freddie Mac Foundation Frederick HarroklFamlly Fund Fund For Eltedna Garemment The GaeO Foundation

The Gal twin Honman Foundation, Inc.


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PRWeb

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Online manly Sent Venus

ASPCA® Releases New Data Concerning Spot-On Flea and Tick Control Cats more susceptible to major illness as a result of inappropriate use.

New York, NY (VOCUS) June 3, 2009

Ca ShareThis Email PDF LS Print

The ASPCA® (The American Society for the Prevention of Cruelly to Anirnalsn today retained dale demonStrating that Cats are more susceptible to illness and death as a result of the misuse of spot-cn Sea and tick control products. The data, collected by the ASPCA Animal Poison Conga Center, also Indicate the ovenvhebring majority of animal ainesses associated with popes use of spot-on Ilea and fir* control products are mild, The EPA has recently slated on heir wab ate that they are Intensiryng their scrutiny of topical sPiation products.

'Products labeled for dogs must never be used on cats-- doing so can result in serious illness and even death." says C. Louse Many. Medical Director of the ASPCAS Bergh Memorial Anhui Hospital. "A veterinarian must Stays be consulted before using spot-on flea and SOS treatments on very yawn old, sick or pregnant pets."

The ASPCA receives morn than 700 calls daily from veterinarians and pet parents. resulting In over 150.000 annual cases Monne medications, insecticides plants and foods. ASPCA epitlamiobget Dr, Minaret Sisteranalyzed data from public calls Manned by the ASPCA regarding flea and tick products. The data identified two key findings. Wise cats ease mated Inaralmirodatery (not per label directbm). they are significantly more Way to experience severe reactions: no liness despite a call to the ASPCA (18%), mild illness (17%). moderate inns (45%), major Men (19%). and death (2%). Mien dogs and cats ware treated correctly (per label directions), the likelihood of Severe adverse reaction was signikantly less: no Illness despite a cal to the ASPCA ( 7 %), mild illness (59%), moderate Illness(22%), Major Mess (2%). and death (0.

'Pm impataM take home message is that although adverse reactions can occur wren al flea and tick products, most effects are relatively mid and Inducts skin initafien end stomach upset" says Dr. Steven Hansen, ASPCA veterinary toxicologist and Senior Vice President Animal Health Services. 'Pet parents should not discontinue using products as directed by the product label when faced with a flea infestation."

Using products as directed and making necessary adjustments based on health we greatly reduce adverse reactions from flea an tick or any Other Medical products. Fleas cause /scene 00w blood counts). carry tapeworm, aid can transmit Infections such as Bartonella; licks transmit many diseases in lading Lyme Disofee and Rocky !fountain Spotted Fever T e risk to pets from these diseases is greater then the risk of adverse reactions when products am use appropriately.

About the ASPCA® Founded In 1565, the ASPCA® (The American Society for the prevention of Cruelty to Animal stn was the first humane organization established in the Ambicat and today has more than one million supporters Oomph:tut Norlh America. A 501 (ells) not-for-profit oorporetion, the ASPCA's mission is to provide effective means for the prevention of cruelty to anima's throughout the Unice Slates. The ASPCA provides local end national laadernip In animal-assisted therapy. animal banns. animal poison control ens-suety, humane education. legislative Settings. and shelter out-each. The New Yolk City headquarters houses a full-service, accredited, anima, hospital, adoption canter, and mobile dine outreach program. The Humane Law Enforcement department enforces NM Yaks

television Series "Animal Precinct' an Animal Planet. For more infonneVon, please visit late anwoespavarg .

Media Contact Nista Maloney (212) 6767700 x Ed. 4579

INtlt

Share llll t E .h, irk 4L i1 S

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Nista Maloney American Society for the Prevention of Crony to Animals 212478-7701 ext. 4670 Email

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it II Products labeled for dogs must never be used on cats—doing so can result in serious illness and even death fp

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