Los Angeles herald., 1910-09-13

jamin E. Neal of the Gatlin Institutes
secret formula, remedy and method of
treatment. That the defendants have
also wrongfully and fraudulently con-
spired to compound and sell said rem
edy under the name of the Neal 3-Day
Liquor Habit Cure or some name sub
stantially similar thereto; that the de-
PENDANTS have organized or caused to
be organized numerous other corpora
tions in various other parts of the
country to use and administer said
remedy under the name or guise of
the Neal Cure, Neal Liquor Habit Cure
or some name substantially similar
thereto. That the remedy compound
ed, used and administered by the de-
PENDANTS and each of them, and by
their allied and subsidiary corporations
is the same remedy, or essentially the
same as to its component and propor-
tionate parts, and administered In like
manner as the Gatlln remedy or treat
ment, and is founded whelly upon the
knowledge acquired by Benjamin E.
Neal while a confidential employe of
the Gatlin Institute company or its
manager.
CLAIMS CONSPIRACY
The complaint further alleges that
the defendant Stiles and defendant
James E. Bruce and Andrew p MABEL
knew at the time of their conspiring
together that the knowledge of said
remedy and use and application of
same we're obtained by BENJAMIN E.
Neal wholly while in the employ of the
plaintiff and its predecessors in inter
est, while sustaining confidential rela-
tions with the plaintiff, and that the
disclosing of said secret formula, rem
edy and the use and application of the
same would be a violation of the afore-
said agreement and understanding
would be breach of good faith and a
violation of good morals.
SIMILARITY OF PACKAGES, DIREo-
TIONs, ETC
The complaint alleges that the Neal
treatment is put UP in boxes Identical
in size, shape, color and interior ar
rangement and in the same number of
bottles with similar marks and labels
as the Gatlin treatment, and that the
Neal treatment report blanks and in
structions are substantially the same
as those used by the Gatlin Institute
and are couched In substantially the
same language.
ASKS 100000 DAMAGES
Section 1s of the complaint states
that the Gatlin Institute company of
America corporation has been dam
aged in the sum of one hundred thou
sand dollars by the acts and things
hereinbefore stated and set forth, and
if permitted to continue will result in
great and irreparable damage to plain
tiff.
WHAT THE GATLIN COMPANY ASKS OF
THE COURT
First-That the defendants. their Of
ficers, agents, employees, servants and
confederates be forever enjoined and
restrained from selling, compounding
and using said secret formula, and
from using and administering the rem
edy compounded from said secret for
mula, and from using and administer
ing the remedy and medicine COM
pounded from said secret formula in
accordance with said secret method
and system of administering the same,
and that Benjamin e. Neal be enjoined
and restrained from disclosing to his
co-defendants, or to anyone else any
knowledge acquired directly or in
directly by reason of his employment
by the Gatlin Institute company at any
time, or by the confidential relations
had with the plaintiff or any of it's
officers
Second-That a temporary injunction
may issue herein against the acts and
things aforesaid during the tendency
of this action.
Thrd-For such other and further
relief as may be just in the premises.
Fourth-And for the sum of one hun
dred thousand dollars damages by
reason of the acts aforesaid, together
with the costs Of this ectten.