John Kennedy is hereby made a defendant on the charge stated below. Choline chloride, or vitamin B4, is sold by manufacturers and resellers to customers in the animal nutrition industry.
Choline chloride is an ingredient necessary for the proper growth and development of animals.
During the relevant period, John Kennedy was initially employed as the Product Manager for choline chloride for BioProducts, Incorporated, a United States corporation with its principal place of business in Fairlawn, Ohio. Ltd. Chinook Group, Inc.'s principal place of business is in White Bear Lake, Minnesota. Chinook Group, Ltd., headquartered in Toronto, Canada, is a limited partnership that was formed in and is currently organized and existing under the laws of Ontario, Canada. Chinook Group, Ltd. manufactures choline chloride in Toronto, Canada and, in conjunction with Chinook Group, Inc., is engaged in the sale of choline chloride throughout the United States and elsewhere. Various corporations and individuals not made defendants herein participated as co-conspirators in the offense charged herein and performed acts 8.