B.J. Penn argues that not only was Georges St. Pierre illegally greased during their UFC 94 title showdown, the Montreal fighter also "ingested a substance that would cause his body to become highly and unnaturally slippery" during the bout.

The Penn camp does not specify what that might be in its 20-page formal complaint to the Nevada State Athletic Commission, which contends the St. Pierre win should be changed to a no contest.

Penn also argues that St. Pierre's alleged cheating is akin to using banned steroids.

"It is Penn's belief . . . that the unfair, illegal and unsanctioned advantage created by (St.) Pierre 'greasing up' or applying or having applied to his body a slippery substance is no difference than an unarmed combatant using steroids to gain an unfair, illegal and unsanctioned advantage over his opponent," Penn's lawyer writes.

Penn's camp has argued since the Jan. 31 TKO loss that their fighter was unable to use his considerable jiu-jitsu skills on St. Pierre because the Canadian was greased up.

St. Pierre and his handlers have denied any wrongdoing.

Commission officials entered the cage the night of the fight, fearing Vaseline was being transferred onto St. Pierre's back between rounds by one of his cornermen. St. Pierre's camp says Phil Nurse, the cornerman in question, was rubbing his back as part of a breathing exercise and that if there was any Vaseline transfer, it was accidental and not enough to make a difference.

They also note commission officials wiped St. Pierre down after the second and third rounds. The fight was stopped after the fourth.

In the formal complaint, Penn's camp dismisses the contention that the greasing was accidental, calling it "a calculated strategy and an intentional act by (St.) Pierre."

In addition to greasing, the complaint says St. Pierre "received excessive or undue spraying or throwing of water" between rounds.

The complaint also says Penn suffered a "cranial concussion," alleging it came about because the Hawaiian fighter could not properly defend himself against his greased opponent.

Raffi Nahabedian, Penn's lawyer, first submitted a letter Feb. 3 to the commission, asking for a "comprehensive investigation and review of the activities involving and relating to Georges St. Pierre prior to and during the bout."

Nahabedian says the initial letter was intended "to put the commission on notice" while a formal complaint was prepared.

Essentially the complaint completes the Penn pleading before the commission. And by following all of the proper complaint procedural requirements, it allows Penn to pursue other appeal options if the commission does not further pursue the complaint.

Prior to receiving the formal complaint, commission executive director Keith Kizer said the matter would be heard at a meeting of the commission March 17.

St. Pierre won when the bout was stopped after four rounds by referee Herb Dean, on the advice of the ring physician. The Penn camp concurred.

The judges scored the first four rounds 40-35, 40-34, 40-34 for St. Pierre, who dominated the fight.

The fight pitted champion against champion. Penn holds the UFC title at 155 pounds while St. Pierre is champion at welterweight at 170 pounds. Both fighters kept their belts, since the fight was contested at 170.