Case 2:20-cv-02366 Document 1 Filed 07/28/20 Page 1 of 24 

UNITED STATES DISTRICT COURT 

FOR THE DISTRICT OF KANSAS 

FEDERAL TRADE COMMSSION Case No._______________ 

Plaintiff, COMPLAINT FOR PERMANENT 

INJUNCTION AND OTHER EQUITABLE 

v. RELIEF 

SUPERIOR PRODUCTS 

INTERNATIONAL II, INC., a corporation, 

and 

JOSEPH E. PRITCHETT, individually and 

as an officer of SUPERIOR PRODUCTS 

INTERNATIONAL II, INC., 

Defendants. 

Plaintiff, the Federal Trade Commission (“FTC”), for its Complaint alleges: 

1. The FTC brings this action under Section 13(b) of the Federal Trade Commission 

Act (“FTC Act”), 15 U.S.C. § 53(b), to obtain permanent injunctive relief, rescission or 

reformation of contracts, restitution, the refund of monies paid, disgorgement of ill-gotten 

monies, and other equitable relief for Defendants’ acts or practices in violation of Section 5(a) of 

the FTC Act, 15 U.S.C. § 45(a). 

2. Defendants market their Super Therm and Sunshield roof and wall coatings using 

deceptive energy savings claims and claims related to R-values, which measure the insulating 

ability of a material, including home insulation. 

3. Defendants claim that their Super Therm and Sunshield products provide 

significant energy savings for consumers when applied to a home or other building. They also 

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claim those products have R-values and R-value equivalents of R-19, and consequently, also 

provide significant energy savings for consumers when applied to a home or other building. 

4. However, these claims are false. Therefore, Defendants cannot substantiate them. 

In fact, Defendants’ coatings have R-values that are substantially less than one when applied as 

Defendants instruct, and Defendants’ purported substantiation demonstrates their products do not 

provide the advertised energy savings. 

JURISDICTION AND VENUE 

5. This Court has subject matter jurisdiction pursuant to 28 U.S.C. §§ 1331, 1337(a), 

and 1345. 

6. Venue is proper in this District under 28 U.S.C. §§ 1391(b)(1) and (c)(2). 

PLAINTIFF 

7. The FTC is an independent agency of the United States created by statute. 15 

U.S.C. §§ 41-58. The FTC enforces Section 5(a) of the FTC Act, 15 U.S.C. § 45(a), which 

prohibits unfair or deceptive acts or practices in or affecting commerce. 

8. The FTC is authorized to initiate federal district court proceedings, by its own 

attorneys, to enjoin violations of the FTC Act and to secure such equitable relief as may be 

appropriate in each case, including rescission or reformation of contracts, restitution, the refund 

of monies paid, and the disgorgement of ill-gotten monies. 15 U.S.C. § 53(b). 

DEFENDANTS 

9. Defendant Superior Products International II, Inc. (“Superior Products”) is a 

Kansas corporation with its principal place of business at 10835 W 78th St, Shawnee, Kansas 

66214. Superior Products transacts or has transacted business in this District and throughout the 

United States. At all times material to this Complaint, acting alone or in concert with others, 

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Superior Products has advertised, marketed, distributed, or sold its Super Therm and Sunshield 

coatings to consumers throughout the United States. 

10. Defendant J.E. Pritchett (“Pritchett”) is the President and founder of Superior 

Products. At all times material to this Complaint, acting alone or in concert with others, he has 

formulated, directed, controlled, had the authority to control, or participated in the acts of 

Superior Products, including the acts and practices set forth in the Complaint. Defendant 

Pritchett resides in this District and, in connection with the matters alleged herein, transacts or 

has transacted business in this District. 

COMMERCE 

11. At all times material to this Complaint, Defendants maintained a substantial 

course of trade in or affecting “commerce,” as “commerce” is defined in Section 4 of the FTC 

Act, 15 U.S.C. § 44. 

DEFENDANTS’ BUSINESS PRACTICES 

12. Defendants manufacture and market coatings designed for residential, industrial, 

and commercial applications, including “Super Therm” and “Sunshield.” 

13. Coating products are marketed for application on homes and buildings and 

include paint, paint with additives (such as ceramic spheres), varnishes, lacquers, and products 

that incorporate such coatings. 

14. Defendants claim that Super Therm is a water-borne combination of aliphatic 

acrylics, urethanes and resin additives that contains four types of ceramic particles that allow it 

“to block heat gain into the surface upon which the coating film is applied.” Defendants also 

claim that Super Therm is an “[i]nsulation coating to create [sic] thermal barrier on substrates,” 

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including “[a]s a one-coast insulation system on exteriors” and “[a]s an insulation system for 

interior applications.” Super Therm retails for $108.50 per gallon. 

15. Defendants claim Sunshield is a water-borne combination of elastomeric acrylic 

and resin additives that includes four different ceramics that provide it “both heat reflectivity and 

insulating properties.” On their website, Defendants claim that Sunshield has “similar 

performance characteristics to Super Therm,” but does not provide “the same benefits.” 

Sunshield retails for $60 per gallon. 

16. Since at least 2008, Defendants have disseminated or caused the dissemination of 

advertising, packaging, and promotional materials for Super Therm and Sunshield, including 

through advertisements on their website and marketing materials for their distributors. 

17. In these materials, Defendants describe Super Therm’s performance in terms of 

R-values and R-value equivalents. For example, they advertise that Super Therm provides a 

“benefit comparable to R 19” when applied 0.01 inches thick. Exhibit A at 1. 

18. R-value is a measurement of resistance to heat flow. See FTC’s Trade Regulation 

Rule Concerning the Labeling and Advertising of Home Insulation (“R-value Rule” or “Rule”), 

16 C.F.R. Part 460 (initially issued in 1980 and last amended in 2019). The greater the R-value, 

the greater the reduction in heat flow, and the more energy may be saved to heat or cool a 

building. 70 Fed. Reg. 31,258 (2005). 

19. Different products have different R-values. For example, fiberglass batt is among 

the most common insulating materials in the United States. It generally has an R-value of R-3.0 

to R-3.8 per inch. Other popular insulation materials, polyisocyanurate or polyurethane foam, 

have R-values of R-5.6 to R-8.0 per inch. Consumers typically apply those materials several 

inches thick to provide the desired level of insulation. By comparison, hardwood has an R-value 

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of R-0.9 per inch. Poured concrete has an R-value of about R-0.08 per inch, making it a poor 

insulator. 

20. The U.S. Department of Energy recommends levels of insulation for homes. It 

divides the country into eight climate zones and lists R-values for each zone. Most of Kansas is 

in Zone 4. The Department recommends homes in this zone have R-38 to R-60 insulation in the 

attic and R-13 to R-15 insulation in the walls. Thus, if such a home uses fiberglass batt (at R-3.8 

per inch), it should have at least 10 inches of the batt in its attic. By comparison, Miami, Florida 

is in Zone 1 where the Department recommends R-30 to R-49 for attics. For the coldest zone, 

Zone 8, the Department recommends attic insulation of R-49 to R-60. 

21. Defendants’ conduct is ongoing as of the filing of this Complaint. 

22. Based on the facts and violations of law alleged in this Complaint, the FTC has 

reason to believe that Defendants are violating or are about to violate laws enforced by the 

Commission. 

DEFENDANTS CLAIM SUPER THERM HAS AN R-VALUE OF R-19 

OR IS EQUIVALENT TO R-19 AND THAT SUNSHIELD IS SIMILAR 

23. Defendants claim in marketing materials that a 0.01-inch thick coat of Super 

Therm provides a “benefit comparable to R 19,” has “a R-19 [e]quivalent [r]ating,” and has the 

same insulating qualities as six inches of “traditional fiberglass insulation.” See Exhibit A at 1; 

Exhibit B at 6. 

24. Defendants claim Sunshield is a “[c]ost-efficient alternative with similar 

performance characteristics to Super Therm.” 

25. In 2008, Superior Products started using a brochure, which it posted on its 

website – where it remained until the FTC contacted Defendants in April 2019 as part of the 

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TESTS AND CERTIFICATIONS (partial list) 

1. Exterior insulation against Solar Radiation - benefit comparable to 

R 19 

2. Blocks 99.5% of infrared I up to 68% sound blockage 

3. lnterior- ASTM C1363 (Guarded Hot Box). E1269 and E1461-92 

(Blocking heat through coating Film 

Case 2:20-cv-02366 Document 1 Filed 07/28/20 Page 6 of 24 

investigation that lead to this suit. That brochure expressly claims Super Therm has “a R-19 

[e]quivalent [r]ating” when applied 0.01 inches thick. See Exhibit B at 6. 

26. Superior Products bolstered this claim by stating in the same brochure that Super 

Therm is “Approved” to have an “RE19” R-value at a 0.01-inch thickness, with “RE” meaning 

an R-value equivalent. Exhibit B at 5. 

27. The 2008 brochure further claims Super Therm has an “RE19” R-value whether 

applied to the “[i]nterior” or “[e]xterior” of a building. Exhibit B at 5. It explains this feature 

by claiming, “SUPER THERM holds heat inside the room in the winter by not loading the heat 

which would be absorbed into the wall to be transferred and lost to the cold. The ceramics will 

not load the heat and allow the normal transfer.” Exhibit B at 4. In this way, Defendants market 

Super Therm not merely as a product that reflects the Sun’s heat, but as a product that performs 

as traditional home insulation. 

28. The 2008 brochure remains on the website of some Superior Products distributors. 

29. Pritchett stated his goal when developing Super Therm was to create a product 

“that could compete with or compliment batt forms of installed insulation.” 

30. Superior Products also created a “Technical Data Sheet” about Super Therm that 

it posted on the company’s website and includes with shipments of Super Therm. Under “Tests 

and Certifications,” the March 1, 2019 version of the data sheet claims: “Exterior insulation 

against Solar Radiation – benefit comparable to R 19” and references several standardized test 

methods used to determine R-value. Exhibit A at 1. 

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31. A video on Superior Products’s website, as of April 2019, claims: “With one 

coating [of Super Therm] at 16mils wet, or 10mil dry, you’re going to get an R-20 R-factor 

equivalence.” 

32. Pritchett personally makes unsubstantiated R-value claims about Super Therm. 

An article about Super Therm on www.bobvila.com, a popular home improvement website, 

quotes Pritchett throughout and states: “SuperTherm achieves an R-19 rating with one coat 

applied, and a rating of R-28.5 when the surface is coated on the exterior and interior.” See 

Exhibit C at 1-2. 

33. In a patent application to the U.S. Government for a method of applying a 

coating, Pritchett claims: “it has been found that the equivalent R value (thermal resistance) of a 

single coat of Super Therm® is R-19 equivalence.” 

34. Defendants bolster their express R-value claims by comparing Super Therm to 

products with known R-values and implying that Super Therm has that level of R-value. 

35. Traditional fiberglass insulation, for example, has an R-value of about R-3.0 per 

inch; six inches of that insulation is R-18. Pritchett claims Super Therm has an R-value of 

“about that of a fiberglass batt having a thickness of six inches.” 

36. Until contacted by the FTC, the Superior Products website repeated Pritchett’s 

six-inch claim, in which it claimed: “A layer of Super Therm, the thickness of a business card, 

has the same insulation value as 6 inches of traditional insulation by blocking the initial loading 

of heat so that the heat available for conduction is reduced.” The 2008 Super Therm brochure 

mirrors that claim, stating, “[i]n fact, a layer of SUPER THERM no thicker than a single 

business card provides the same protection as 6 inches of fiberglass,” accompanied by the 

following visual and express “R-19 Equivalent” claim: 

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THICKNESS OF SUPER THERM® 

--

(EQUAL TO) 

~ THICKNESS OF TRADITIONAL FIBERGLASS INSULATION~ 

I r I I ; I I I I I I I ~I . I I I I ~I I I I I I ~I ' I I l I I ~r I I I ~I 

ArrLY I\ R· 19 EQ!JIV/\L[NT RATING TO YOUR FACILl'IY WITH I\ SINGLE COAT! 

With the ability to protect from all 3 methods of heat transfer, SUPER THERM is proven to outperform 

1radilional iibcrglass insulaticm. In iact, a laycr oi SUPER TH ERM n,11hic-kcr than a single business card 

provides the same protection as 6 inches uf iibcrglass. And while" moisture content oi 1.5?1, iu ti bcrglass i-cduccs 

its effectiveness by 3,'>I',, SUPER THERM' is specifically for111ula1cd to prevcnl moistu re absurptlon. 

Case 2:20-cv-02366 Document 1 Filed 07/28/20 Page 8 of 24 

Exhibit B at 6. 

37. In addition, the product label on containers of Super Therm in 2019 claims: 

“Insulating equivalent better than batt insulation due to [heat] load reduced.” 

38. Defendants make further claims in the 2008 brochure and on their website as late 

as April 2019, including expressly claiming Super Therm has an “RE19” R-value and suggesting 

it is equivalent to ten inches of fiberglass (R-value of approximately R-30), eight inches of 

cellulose filler (R-value of approximately R-25), and 5.5 inches polystyrene foam (R-value of 

approximately R-25) by using the visual below: 

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~ 

~ ~ ~ ~ ,l' . <- ,,,; 

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At,9.~. IG-ffiltCOl1 (t..._tef10f Apo}~• ✓ ("\l ('\ J (\) (\) 

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~ M Oht d. ~_.'!!4 bbl 'M'!'IIII ✓ '1 (\ I '1 

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K llled ,r fl.-ne sc,eac ./ I "'\I '\ I / N 

~ 2000 M 0, Y!t "f#a, tdl1nt ✓ ~I ,, I -J N 

US04- ✓ - - - - ~-- ✓ N (\.) ✓ (\) 

81Cc:b 99 5,,_ d fl'it•CICI r'ar,o ✓ - - - - ~tM."\A"dd" ""~ ✓ ~ N ✓ N 

., r-.ttt(W&tK1.1Ct) [ 0 ( , /l I [I J 1:\) 0.?8 

25 ~ r~I l ilt ape(\M'C)' ✓ - - I~ -

Case 2:20-cv-02366 Document 1 Filed 07/28/20 Page 9 of 24 

Exhibit B at 5. 

39. When contacted by the FTC, Defendants removed certain R-value claims from 

their website. Nonetheless, R-value and R-value equivalent claims still appear on Superior 

Products’ website and, as late as October 2019, in its technical brochure for Super Therm 

(claiming “R 19” equivalency). For example, a part of Defendants’ current website sub-titled, 

“Reflective Coating vs. Fiberglass vs. SUPER THERM,” compares fiberglass insulation to Super 

Therm. Defendants state “Fiberglass has only an ‘R 19’ value when it is a full 6 inches.” They 

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then claim that a 0.01-inch coating of “Super Therm was tested in the lab and found to have” a 

“better” R-value, by about 70%, than a test sample of 3-inches of fiberglass. 

DEFENDANTS CLAIM THAT SUPER THERM AND SUNSHIELD 

SAVE CONSUMERS MONEY 

40. Defendants claim that using Super Therm “reduc[es] important energy costs,” 

results in “[e]nergy savings,” and brings about “cost-saving, long-term energy efficiencies.” See, 

e.g., Exhibit D at 2. They also claim that Sunshield provides “similar performance 

characteristics to Super Therm.” 

41. In 2015, Defendants added a second brochure to their website, which remains on 

the site today. This brochure makes energy savings claims about Super Therm. Under the 

heading “PROVEN ENERGY EFFICIENCY,” the brochure claims a “26% - 30% increase in 

energy efficiency” in “Interior Temperature Performance” attributed to analysis by the U.S. 

Department of Energy. Exhibit D at 4. It also claims “22% overall energy reduction with 40% 

HVAC savings” as a result of Super Therm being applied at an airport terminal. Exhibit D at 4. 

42. Defendants also included on their website (as of April 2019) a number of specific 

claims about substantial energy savings achieved by using Super Therm, for example: 

a. Under the title, “Energy Saving Products,” the website claims “[s]hown in field 

usage to save between 40% and 70%.” 

b. “Energy Efficient – Energy savings of 20-70% (field results as given by 

customers’ own testing, such as Sony.” 

c. “FACT: Sony Corporation coats roof and walls of one monitored building with 

SUPER THERM and finds a 78% reduction in total energy consumption.” 

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d. “FACT: Florida Department of Energy Specialist documents . . . 30% utility 

savings on homes in Florida (hot humid climates) and in Denver (dry climates) as 

well as steel containers.” 

e. “FACT: German Mechanical Engineer in Construction Physics makes study of 

home coated with SUPER THERM and finds 76% less energy usage from 

SUPER THERM as compared to fiberglass and rock wool.” 

f. “FACT: Total house application cost is paid with energy savings in 2-4 years.” 

43. Pritchett has personally made energy savings claims about Super Therm. On the 

popular home improvement website, bobvila.com, Pritchett claims: “We estimate that a home 

can save up to 40 to 50 percent in energy costs using our product.” Exhibit C at 2. 

44. After the FTC identified the claims in Paragraph 42, Superior Products removed 

them from its website, but maintained other energy savings claims. For example, Defendants 

continued to claim that applying Super Therm to the roof of a building resulted in “total utility 

savings of $22,144 (22%) in August for the total facility and the A/C portion of the total utility 

being 55%, this relates to a 40% savings in A/C operational cost.” 

DEFENDANTS CLAIM THAT TESTING ESTABLISHES THEIR R-VALUES 

45. Defendants expressly claim that testing supports their R-value claims of R-19. 

46. For example, Superior Products created a March 1, 2019 “Technical Data Sheet” 

about Super Therm, which it posts on the company’s website and includes with shipments of 

Super Therm. Under the heading, “Tests and Certifications,” the data sheet claims: “Exterior 

insulation against Solar Radiation – benefit comparable to R 19.” Exhibit A at 1. 

47. In support of Superior Products’ R-value claims, Defendants have circulated to 

their distributors several letters and reports purporting to show that Super Therm has an R-value 

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of R-19. For example, in January 1997, the Thermophysical Properties Research Laboratory, 

Inc. (“TPRL”) produced a report for Superior Products titled, “Thermophysical Properties of 

SUPER THERM Coating, Report No. 1780.” Although the report does not state an R-value or 

even use the term “R-value,” Defendants provided the report to distributors and used it in a 

promotional video also given to distributors in which Defendants claim the report supports their 

R-19 claims. 

48. On March 7, 1997, a TPRL researcher wrote a two-sentence letter to Defendants 

that contained an R-19 claim, which Defendants then circulated to distributors. The letter states: 

I have reviewed the information provided by Superior Products 

International II, Inc. on the thermal performance of Super Therm. 

The combination of it’s[sic] reflectivity, emissivity and thermal 

conductivity allows it to be a thermal resistor as effectively as 

fiberglass with a R 19 rating as shown by the Hot Box Test. 

49. Superior Products also circulated a one-page letter from VTEC Laboratories, Inc. 

to its distributors. The January 28, 1998 letter claims: “As stated in the testing report performed 

at the [sic] Thermophysical Properties Research Laboratory, Inc., the calculated R-value [of 

Super Therm] is to be RE-19.” Superior Products created a video that visually showcased the 

afore-quoted sentence and the January 1997 TPRL report, with the voiceover claiming: 

In fact, independent laboratory tests, such as the one conducted by 

Thermophysical Properties Research Laboratory reported that 

Super Therm stopped 99.5% of the heat conducted in their tests. In 

fact, Thermophysical Properties Research Laboratory conducted a 

test that clearly and unequivocally proved that a coat of Super 

Therm with a thickness no bigger than the a human hair produces 

an insulation rating that is equivalent to six to eight inches of 

comparable fiberglass insulation. Imagine that. Super Therm 

stops heat better than a wall full of harmful fiberglass insulation. 

50. Later, Defendants circulated to distributors a May 2, 2013 two-sentence letter 

from VTEC Laboratories, Inc. to Pritchett, which claims: “SuperTherm can perform as an 

equivalent R 19 based upon application and test method.” 

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51. In or about 2017, Superior Products circulated to its distributors a report prepared 

for it by Inn Choi, Ph.D, in which Choi claims, “a 10-mil [0.01-inch] thickness of SuperTherm is 

the same as 6 [inches] of fiberglass in Thermal Conductivity.” Choi states that he did not 

conduct independent testing, and instead reviewed summaries of tests by others provided to him 

by Defendants without access to the test reports. At least one distributor then posted the report 

on its website. 

52. Superior Products also claims that testing supports its R-value claims by 

comparing Super Therm to known insulation materials. Defendants’ 2008 brochure claims, for 

example, states: “Tests prove it. SUPER THERM is the better option.” This appears next to a 

visual (shown above at ¶ 38) comparing a 0.01 thick coat of Super Therm to 10” fiberglass 

insulation, 8” of cellulose insulation, and 5.5” of polystyrene foam insulation. Exhibit B at 5. 

The brochure further claims: “SUPER THERM outperforms and outlasts traditional insulation in 

lab tests and on the field.” Exhibit B at 6. 

53. After the FTC contacted Superior Products on their website and marketing 

materials, Defendants continued to claim that testing supports their R-value claims for Super 

Therm. In a “Thermal Tutorial” section of Defendants’ website, they claim that “Super Therm 

was tested in the lab and found to have” a “better” R-value, by about 70%, than a test sample of 

3-inches of fiberglass. 

54. Additionally, Defendants claim that NASA testing supports their insulation 

claims. A page of Superior Products’s 2015 brochure compares Super Therm to “traditional 

insulation” and Defendants claims: “Super Therm passed NASA testing with Best Test Result.” 

Exhibit D at 3. Next to that claim is a picture of the Space Shuttle. Defendants claim that Super 

Therm is based on the ceramics used by NASA to protect the Space Shuttle and that “Super 

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Case 2:20-cv-02366 Document 1 Filed 07/28/20 Page 14 of 24 

Therm® was designed and developed with the assistance of NASA, a fact that can be 

substantiated.” 

DEFENDANTS USE A NETWORK OF DISTRIBUTORS TO SPREAD THEIR CLAIMS 

55. Superior Products sells Super Therm across the United States through authorized 

distributors and provides them with marketing materials. Internationally, the company claims to 

have distributors in at least 40 countries. 

56. Superior Products provided its distributors with product brochures, reports, letters, 

graphs, charts, and videos created by or for Superior Products that contain Defendants’ claims. 

The distributors, in turn, spread those claims throughout the United States. Predominately, they 

did this on their own websites, oftentimes using the exact materials and wording created by 

Defendants. 

57. Superior Products has 15 distributors who sell its products in the United States. 

58. Eleven of those 15 distributors have identifiable websites. Of those 11, eight 

prominently repeated Defendants’ R-value and energy savings claims in April 2019 or later. 

They do this often by re-publishing Defendants’ materials or making claims based upon the 

materials distributed by Defendants. For example: 

a. Arizona Superior Coatings claims that Super Therm has an “R-19 equivalent 

rating. (Equal to 6-8 inches of fiberglass)” when applied 0.01 inches thick. The 

distributor claims Super Therm is “Approved” to achieve an “RE19” rating when 

applied to the outside or inside of a building. The distributor makes multiple 

energy savings claims about Super Therm, such as “SAVE UP TO 35% ON 

YOUR UTILITY BILLS!” and that it produces “[e]nergy savings of 20-70% for 

air-conditioned buildings.” It also claims: “Super Therm can be used as 

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replacement for traditional insulation on most substrates and in most conditions.” 

The distributor’s website includes three videos. In the first, the distributor’s 

owner, Gary Collins, claims: “when applied to your home, you can experience as 

much as a 45-50% reduction in your utility bill.” In the second video, it is 

claimed “[w]ith one coating at 16mils wet, or 10mil dry [i.e., 0.01 inches], you’re 

going to get an R-20 R-factor equivalence.” In the third video, it is claimed that 

Super Therm “achieve[s] an R-19 insulation value, as tested by independent 

laboratories, or the equivalent of 6-8 inches of traditional fiberglass batt 

insulation, with merely a 7 dry mil [i.e., 0.007 inches] coating.” 

b. Coating Solutions of Texas claims that using Super Therm provides insulation 

“[c]omparable to an R19 effect” and that it can be used to “replac[e] the 6 to 8 

inches of traditional insulation to block initial heat load.” The distributor 

republishes a document prepared by Superior Products that claims: “Super Therm 

has a “R-19 Equivalent Rating (equal to 6-8 inches of fiberglass)[sic] Thickness 

of a business card, but outperforms fiberglass in laboratory and field testing;” 

“SUPER THERM (R-19);” and “Super Therm is a certified insulator providing an 

R-19 equivalent.” The distributor also claims, “Super Therm® can provide 

energy savings of 20-70%.” 

c. DW Pearce Enterprises Ltd. dba Eagle Specialized Coatings and Protected 

Environments of Canada (serving parts of the United States) republishes many of 

the R-value tests and documents prepared by or for Superior Products. These 

documents claim “R19 is achieved” using Super Therm or that “RE19” is possible 

with a coating 0.01-inches thick. The distributor further claims Super Therm is a 

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“RE19 [n]on-deteriorating [i]nsulation,” has a “[t]hermal [b]enefit [e]quivalent to 

R19,” “provides a thermal benefit equivalent to R19 at the very least,” and that 

painting asphalt roof shingles with Super Therm provides “an additional 

EFFECTIVE R19 insulation.” It also claims, based on purported testing paid for 

by Superior Products, “[w]hen SuperTherm is applied at 10 mils [0.01 inches], the 

improvement to the R Value [of the material to which it is applied] is 68%. Based 

on the 68% improvement ratio, a minimum R13 material improves to R21.8 by 

applying 1 coat of SuperTherm.” Elsewhere the distributor claims applying Super 

Therm to a building will result in “making a 60% improvement” in the structure’s 

R-value. The distributor also includes an article attributed to bobvila.com with 

the claim: “SUPER THERM . . . carries an R value of R-19.” 

d. Innovative Coatings Technologies of Colorado claims Super Therm has an “R19 Equivalent Rating (equal to 6-8 inches of fiberglass),” an “R-19 equivalency,” 

and provides an “insulation value equivalent to R19” when applied 0.01 inches 

thick (“only the thickness of a business card”). The distributor also claims that 

using Super Therm “[s]aves [e]nergy [u]sage of 20-70% for air-conditioned 

buildings during the warmer months, averaging 25%-35% annual total utility 

savings.” It repeats other energy savings claims made by Superior Products, such 

as “30% utility savings on homes in Florida,” “76% less energy usage as 

compared to fiberglass and rock wool” in a home, and a “78% reduction in total 

energy consumption” of a commercial building. 

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e. RBG Constructors, Inc. of Mississippi has a video with the following statement 

about Super Therm: “With one coating at 16mils wet, or 10mil dry, you’re going 

to get an R-20 R-factor equivalence.” 

f. Superior Coatings International, Inc. of California claims Super Therm has an 

“R-19 Equivalent Rating . . . replacing the 6 to 8 inches of traditional insulation to 

block initial heat load” and that “Super Therm has been tested to have an RE-19 

value compared to traditional insulation.” It also makes the claim that “[a] layer 

of Super Therm, the thickness of a business card, has the same insulation value as 

6 inches of traditional insulation.” The distributor repeats claims by Superior 

Products that “Super Therm can provide energy savings of 20-70%,” can result in 

“saving between 40 and 60 percent on your next power bill,” and that “Super 

Therm is 296% more effective than traditional insulation under identical 

conditions and shown to be stable all day in field studies by Sony, UPS and 

others.” 

g. Superior Products Coatings, Inc. of Georgia claims: “Because of special 

ceramic used Super Therm has a high emissivity, the ability to block heat transfer, 

block air and moisture infiltration, this results in a performance, comparison wise, 

of better than a R-19.” The distributor uses the visual shown in ¶ 36, supra, and 

the claim, “[i]n fact, a layer of SUPER THERM no thicker than a single business 

card provides the same protection as 6 inches of fiberglass.” For Sunshield, the 

distributor claims the product “[s]hatters air conditioning costs.” 

h. Superior Coating Solutions LLC of New York claims: “While Super Therm 

handles heat transfer differently than traditional insulation such as fiberglass, 

17 
 

 

 

 

 

 

 

 

 

 

 

Case 2:20-cv-02366 Document 1 Filed 07/28/20 Page 18 of 24 

spray foam, polyisocyanurate, or polystyrene, the overall heat loss/gain or energy 

savings would be comparable to that of using traditional R-19 insulation.” It 

further claims that Super Therm results in energy savings of “20-70% depending 

on use” and claims, “Super Therm is 296% more effective than traditional 

insulation under identical conditions and shown to be stable all day in field 

studies by Sony, UPS and others.” 

59. Additionally, distributors make claims directly to consumers. A Superior 

Products distributor told a consumer in 2017: “The Super Therm coating application is a thick as 

a business card and carrying an Re = 19 which results in a very thin ceramic coating that repels 

sunlight heat and keeps internal heat from escaping through the cold roof.” 

DEFENDANTS’ R-VALUE, R-VALUE EQUIVALENT, AND ENERGY SAVINGS 

CLAIMS ARE FALSE OR UNSUBSTANTIATED 

60. Super Therm and Sunshield do not significantly restrict heat flow, let alone to the 

extent claimed by Defendants. Indeed, the R-value of Super Therm applied to the thickness 

Defendants instruct is considerably less than R-1. 

61. In 2009, the Cold Climate Housing Research Center (“Climate Center”), a group 

not affiliated with Defendants, tested Super Therm and a similar product by a different 

manufacturer. The Climate Center’s report concluded: “Neither product contributed to the Rvalue of the building material on which they were applied” and “[t]he coatings did not 

demonstrate an energy savings in the realistic box tests we conducted.” 

62. In January 2012, TPRL, the laboratory that Defendants claim had determined 

Super Therm has an R-19 value, rebuked Defendants’ claim. Under the title, “Insulation Paint 

Claims,” TPRL posted this warning on its website: 

18 
 

 

 

 

 

 

 

Case 2:20-cv-02366 Document 1 Filed 07/28/20 Page 19 of 24 

Beware of Insulated paint or ceramic type products that claim wild 

insulation values. TPRL Inc. would like to counter misinformation concerning various claims about insulated paint 

products that our company has tested . . . . If you find a copy of 

[sic] TPRL 1780 report [i.e., the report on Super Therm] on the 

web you will notice that no R values are in the report. Our 

company did provide a memo that stated that a R19 value was 

possible under certain conditions which included how the 

HotBox[sic] test was done. The HotBox[sic] test, performed by 

another company, used a coating of insulated paint on top of a[sic] 

insulating media to get a R19 value. In real world conditions you 

will not get a R value of 19 from these insulated paints. 

63. Based on the data compiled by TPRL in its original report, the R-value of Super 

Therm can be determined to be approximately R-0.00265. 

64. In 2017, Superior Products prepared an energy savings analysis for a potential 

client that more accurately reflected the true R-value of Super Therm. In their calculations, 

Defendants identified Super Therm as having an R-value of R-0.00258 when applied 0.01 inches 

thick. 

65. Most recently, Superior Products admitted during the FTC’s investigation: “Super 

Therm is a coating and cannot have a R-value or a R-value equivalency based upon established 

criteria . . . . [Superior Products] clearly understands that a coating such as Super Therm cannot 

have a R-value.” 

66. This admission mirrors a prior acknowledgment by Defendant Pritchett. In 

October 2009, an energy efficiency newsletter published a response by Pritchett to the Climate 

Center report described in ¶ 61, which had concluded after testing that Super Therm did not 

contribute to a building’s R-value. In response, Pritchett conceded: “Super Therm does not have 

an R value because an R value measures only thermal resistance (absorb and resist heat transfer) 

and requires thickness.” 

19 
 

 

 

 

Case 2:20-cv-02366 Document 1 Filed 07/28/20 Page 20 of 24 

67. Despite these concessions, Defendants continued to make numerous R-value, Rvalue equivalency, and energy savings claims in their marketing materials, in public statements, 

and on the Superior Products website when the FTC contacted them in April 2019. While 

Defendants removed some false or unsubstantiated claims, they continue to make others. 

DEFENDANTS’ CLAIMS ARE MATERIAL 

68. Defendants tout their products’ purported R-values, insulating benefits, and 

energy saving capabilities to consumers as a basis of superiority over paints and other coatings. 

69. Defendants state in marketing materials and public statements, for example, that: 

a. “We estimate a home can save up to 40 to 50 percent in energy costs using our 

product.” 

b. Using Super Therm results in a “26% - 30% increase in energy efficiency.” 

c. Using Super Therm results in “40% savings in A/C operational cost” and 22% in 

“total utility savings.” 

d. Super Therm has been “[s]hown in field usage to save between 40% and 70%.” 

DEFENDANTS PROVIDED THE MEANS AND INSTRUMENTALITIES FOR THE 

COMMISSION OF DECEPTION 

70. Defendants provided their promotional materials, third party reports, and related 

documents containing false and deceptive claims to their distributors. 

VIOLATIONS OF THE FTC ACT 

71. Section 5(a) of the FTC Act, 15 U.S.C. § 45(a), prohibits “unfair or deceptive acts 

or practices in or affecting commerce.” Misrepresentations and unsubstantiated claims constitute 

deceptive acts or practices prohibited by Section 5(a) of the FTC Act. 

20 
 

 

 

Case 2:20-cv-02366 Document 1 Filed 07/28/20 Page 21 of 24 

COUNT I 

False or Unsubstantiated Performance Claims 

72. In numerous instances in connection with the advertising, promotion, offering for 

sale, or sale of Super Therm and Sunshield, as described in Paragraphs 23-44, Defendants have 

represented, directly or indirectly, expressly or by implication, that: 

A. Super Therm has an R-value of R-19, or provides a benefit equivalent to R-19. 

B. Sunshield has similar performance characteristics as Super Therm. 

C. Using Super Therm or Sunshield will save consumers a significant amount of 

money, including of up to 78% on existing energy bills. 

73. The representations set forth in Paragraph 72 are false and misleading and were 

not substantiated at the time the representations were made. 

74. Therefore, the making of the representations as set forth in Paragraph 72 

constitute deceptive acts or practices in violation of Section 5(a) of the FTC Act, 15 U.S.C. 

§ 45(a). 

COUNT II 

False Establishment Claim of R-values 

75. In numerous instances in connection with the advertising, promotion, offering for 

sale, or sale of Super Therm and Sunshield, as described in Paragraphs 45-54, Defendants have 

represented, directly or indirectly, expressly, or by implication, that testing establishes an Rvalue or R-value equivalent of R-19 for Super Therm. 

76. In truth and in fact, testing does not establish these R-values. 

77. Therefore, the representations in Paragraph 75 are thus false or misleading and 

constitute deceptive acts or practices in or affecting commerce in violation of Section 5(a) of the 

FTC Act, 15 U.S.C. § 45(a). 

21 
 

 

 

 

Case 2:20-cv-02366 Document 1 Filed 07/28/20 Page 22 of 24 

COUNT III 

Means and Instrumentalities 

78. By furnishing distributors with promotional materials for Super Therm, including 

materials such as brochures and third-party reports, that make false or misleading 

representations, Defendants have provided the means and instrumentalities that constitute 

deceptive acts or practices in or affecting commerce in violation of Section 5(a) of the FTC Act, 

15 U.S.C. § 45(a). 

CONSUMER INJURY 

79. Consumers are suffering, have suffered, and will continue to suffer substantial 

injury because of Defendants’ violations of the FTC Act. In addition, Defendants have been 

unjustly enriched as a result of their unlawful acts or practices. Absent injunctive relief by this 

Court, Defendants are likely to continue to injure consumers, reap unjust enrichment, and harm 

the public interest. 

THIS COURT’S POWER TO GRANT RELIEF 

80. Section 13(b) of the FTC Act, 15 U.S.C. § 53(b), empowers this Court to grant 

injunctive and such other relief as the Court may deem appropriate to halt and redress violations 

of any provision of law enforced by the FTC. The Court, in the exercise of its equitable 

jurisdiction, may award ancillary relief, including rescission or reformation of contracts, 

restitution, the refund of monies paid, and the disgorgement of ill-gotten monies, to prevent and 

remedy any violation of any provision of law enforced by the FTC. 

PRAYER FOR RELIEF 

81. Wherefore, Plaintiff FTC, pursuant to Section 13(b) of the FTC Act, 15 U.S.C. 

§ 53(b), and the Court’s own equitable powers, requests that the Court: 

22 
 

 

Case 2:20-cv-02366 Document 1 Filed 07/28/20 Page 23 of 24 

A. Award Plaintiff such ancillary relief as may be necessary to avert the likelihood of 

consumer injury during the pendency of this action and to preserve the possibility 

of effective final relief, including a preliminary injunction; 

B. Enter a permanent injunction to prevent future violations of the FTC Act by 

Defendants; 

C. Award such relief as the Court finds necessary to redress injury to consumers 

resulting from Defendants’ violations of the FTC Act, including but not limited 

to, rescission or reformation of contracts, restitution, the refund of monies paid, 

and the disgorgement of ill-gotten monies; and 

D. Award Plaintiff the costs of bringing this action, as well as such other and 

additional relief as the Court may determine to be just and proper. 

REQUEST FOR PLACE OF TRIAL 

Plaintiff hereby requests that trial of the above-entitled matter be held in the City of 

Kansas City, Kansas 

* * * 

23 
 

 

 

 

 

 

Case 2:20-cv-02366 Document 1 Filed 07/28/20 Page 24 of 24 

Respectfully submitted, 

STEPHEN R. MCALLISTER 

United States Attorney 

s/ Jon P. Fleenor_________________ 

JON P. FLEENOR #14002 

Assistant United States Attorney 

Office of the United States Attorney 

For the District of Kansas 

500 State Avenue, Suite 360 

Kansas City, KS 66101 

Tel: 913-551-3561 

Fax: 913-551-6541 

Jon.Fleenor@usdoj.gov 

Local Counsel for Plaintiff 

Federal Trade Commission 

Dated: July 28, 2020 

ALDEN ABBOTT 

General Counsel 

s/ Jonathan W. Ware________________ 

JONATHAN W. WARE (DC SBN 989414) 

Pro hac admission pending 

Federal Trade Commission 

600 Pennsylvania Ave., NW 

Maildrop CC-9528 

Washington, DC 20580 

Tel: 202-326-2726 

Fax: 202-326-3197 

jware1@ftc.gov 

Counsel for Plaintiff Federal Trade 

Commission 

24 
 

 

Case 2:20-cv-02366 Document 1-1 Filed 07/28/20 Page 1 of 1 

INDEX OF EXHIBITS TO 

PLAINTIFF FEDERAL TRADE COMMISSION’S 

COMPLAINT 

Exhibit A: Super Therm Technical Data Sheet (3/1/19) 

Exhibit B: Super Therm Brochure (2008) 

Exhibit C: Bobvila.com Article by B. Hardy 

Exhibit D: Super Therm Brochure (2015) 
 

Case 2:20-cv-02366 Document 1-2 Filed 07/28/20 Page 1 of 5 

EXHIBIT A 
Technical Data Sheet {,Vl./li) 

DESCRIPTION 

SUPER THERM® is a water-borne combination of highperformance aliphatic acrylics, urethanes and resin additives which 

produces a tough, yet flexible coating film. Designed for 

performance and durability, SUPER THERM® contains 4 unique 

ceramics to block heat gain into the surface upon which the 

coating film is applied. SUPER THERM® resists 95% of Solar heat 

blocking Visual Light, Ultra Violet (UV), and Infrared (IR). SUPER 

THERM® is a flexible membrane with low permeability that can 

greatly reduce expansion and contraction of a roof, and prevents 

corrosion and surface deterioration. 

TYPICAL USES 

 As a one-coat insulation system on exteriors to block the 

migration of Solar Heat gain (roofs and side walls). 

 As an insulation system for interior applications to seal and 

block IR heat loss and ambient heat loss. 

 For interior insulation uses see number three in testing 

 Exterior application to reduce or eliminate condensation on 

HVAC systems, tanks, spheres, storage systems, and concrete 

walls. 

 As a system over metal, concrete, masonry, and wood to stop 

moisture penetration and corrosion. 

 Ability to resist dirt, mold, mildew, and pollution to increase 

longevity, and reduce surface maintenance. 

,.. As a topcoat over metal roofs, or an intermediate coat on flat 

roofs. 

, Applied over tent fabrics to provide insulation & remain flexible. 

Applied to tilt-up concrete walls to hold interior heat. 

APPLICATION METHODS 

SUPER THERM® can be applied to metal, concrete, masonry and 

wood. The application can be spray, brush or roller. For specific 

instructions on surface preparation, mixing and application, please 

refer to the SPl's application instructions for SUPER THERM®. 

This coating should never be applied at less than 17 mils wet (425 

microns), 10.0 mils dry (250 microns), each coat. 

TESTS AND CERTIFICATIONS (partial list) 

1. Exterior insulation against Solar Radiation - benefit comparable to 

R 19 

2. Blocks 99.5% of infrared / up to 68% sound blockage 

3. lnterior-ASTM C1363 (Guarded Hot Box), E1269 and E1461-92 

(Blocking heat through coating Film 

4. UL (Underwriters Laboratory) approved 

5. Flame Spread Test (ASTM E84; O smoke, O flame) 

6. Class ·A" Flame Spread 

7. Marine Approvals: - American Bureau of Shipping; USCG 

8. UV & Salt Spray Resistance (ASTM 5894) 5000 hours 

9. USDA Approved 

10. Flexibility (ASTM E1737): 180 degree bend-passed 

11. Adhesion ASTM (D4541): 115.2psi, not suitable for films <5 mils 

12. Perm Rating (ASTM d1653-13): 10 dry mils=Bperms; 12 dry 

mils=4perrns 

13. Abrasion Resistance (ASTM D4060): 3,000 cycles 

14. Resistance to Sall Spray: 2,000 hours 

15. Resistance to Wind Driven Rain (ASTM D6904) 

16. Airforce Canopy: MIL-PRF-6799 

PHYSICAL DATA 

• Solids: By weight 70% I By Volume: 60% (+/-2%) 

• 30-60 minutes to tack free at 70°F (21 °C) 

• Overcoat: 2 hours when 70°F (21 °C) at 40% Relative 

Humidity 

• Full Cure: 21 days 

• Lead-, chromate-, and asbestos-free 

• Cures by evaporation 

• Weight 11. 72 lbs. per gallon 

• Vehicle Type: Urethane/Acrylic blend 

• Shelf Life: Up to 5 years if unopened under 

appropriate storage conditions (See MSDS). 

• voe Level: 67.2 grams/liter, 0.561 gal/lbs. 

• Viscosity: 105- 110 KU ; 25,000 Centipoise 

• pH: 8.5 - 9.5 

• 95 sq.ft/gallon (8sqm): 17 mils (425 microns) wet I 

10.0 mils (250 microns) dry 

• Maximum Surface Temperature when applying: 150° F 

(65°C) 

• Minimum Surface Temperature when applying: 40°F 

(5°C) 

• Maximum Surface Temperature after curing: 300°F 

(149°C) 

• Do not apply over 18 mils wet per application. Allow to 

dry down before adding additional thickness. 

MEETS MIL SPEC: MIL-PRF-6799L 

SAFETY PRECAUTIONS 

Do not use this product without first taking all appropriate safety 

measures to prevent property damage and injuries. These 

measures may include, without limitation: proper ventilation, use 

of proper lamps, wearing of protective clothing and masks, tenting, 

and proper separation of application areas. For more specific 

safety procedures , please refer to the SUPER THERM® 

Material Safety Data Sheet. KEEP OUT OF REACH OF 

CHILDREN. 

LIMITATION OF LIABILITY: The information contained in this data sheet is 

based upon tests that we believe to be accurate and is intended for guidance 

only. All recommendations or suggestions relating to the use of the products 

made by SPI. whether in technical documentation, or in response to a specific 

enquiry. or otherwise. are based on data which to the best of our knowledge is 

reliable. The products and information are designed for users having the 

requisite knowledge and industrial skills. and the end- user has the 

responsibility to determine the suitability of the product for its intended use. 

SPI has no control over either the quality of condition of the substrate. or the 

many factors affecting the use and application of the product. Therefore, SPI 

does not accept any liability arising from loss. injury. or damage resulting from 

such use or the contents of this data sheet (unless there are written 

agreements stating otherwise). 

The information contained in this data sheet is subject to modification as a 

result of practical experience and continuous product development. This data 

sheet replaces and annuls all previous issues and the user has the 

responsibility to ensure that this sheet is current prior to using the product. 

Superior Products International II, Inc.• 10835 W. 78th Street• Shawnee, KS 66214 

Website: www.spicoating_s.com • Email: sales_@spi4:;_oatings.com 

Case 2:20-cv-02366 Document 1-2 Filed 07/28/20 Page 2 of 5 

Exhibit A
Application Instructions (1,.,u , 

SUPER THERM® is a water-borne combination of highperfonnance aliphatic urethanes, elastomeric acrylics, 

and resin additives which produces a tough, yet flexible 

coating film. Designed for performance and durability, 

SUPER THERW contains 4 unique ceramics to block up 

to 95% of Solar Heat entering a structure due to Visual 

Light, Ultra Violet (UV), and Infrared (/RJ . SUPER 

THERW is a flexible membrane with low permeability 

that can greatly reduce expansion and contraction of a 

roof, and prevents corrosion and surface deterioration. 

SURFACE PREPARATION 

Surface must be clean from oil, tar, rust, grease, salts, and films. 

I) Use general degreaser if needed. 

2) Clean surface using TSP (tri-sodium-phosphate) or a citrus 

cleaner to release dirt and degreaser residue. 

3) Pressure-wash if possible @ 3500 psi. 

4) Salt contamination on a surface can come as a result of salt 

water, fertilizers, and car exhaust. Use Chlor-Rid or 

equivalent to decontaminate surface if salts are present. 

Acceptable levels: Nitrates: 5-10 mcg/cm2 , Sulfates: 5-10 

mcg/cm2

, Chlorides: 3-5 mcg/cm2 

Surface must be completely dry before applying. 

1) SUPER THERM must be applied during proper 

temperatures (below) and the prescribed overcoat window 

of the coating over which it will be applied. 

2) Maximum Surface Temperature when applying: 150°F 

(65°C) 

3) Minimum Surface Temperature when applying: 40°F (5°C) 

4) Maximum Surface Temperature after curing: 300°F (149°C) 

NOTE: Use Rust Grip® as a primer when needed. Refer to 

Rust Grip technical data sheet for overcoat window. 

NOTE: If pack rust or mill scale exist, it must be removed by grit 

blast, power tool or needle gun. Once removed, begin with 

Step 1 (power wash). 

NOTE: Harsh environments where color is desired, or where 

pooling may occur: SUPER THERM® should be over 

coated with ENAMO GRIP (solvent based) over metal or 

concrete, and SP SEAL COAT over flexible surfaces (foam, 

tar, rubber and wood). 

NOTE: Modified bitumen, asphalt roofing, PVC, TPO and 

single-ply membranes must be primed with the appropriate 

primer (i.e. Super Base/HS or SP Single-Ply Primer). 

MIXING 

SUPER THERM® should be mechanically mixed or mixed by 

hand (boxing) for three minutes, then applied. 

APPLICATION 

SUPER THERM® can be applied by brush, roller or spray; 

however, the preferred method is by air or airless sprayer. It 

should never be applied directly over rust. nor should it ever 

be diluted or thinned. 

1) If application is by brush, use a soft bristle brush. 

2) If application is by roller, use a 3/4 inch nap roller. 

3) If application is by spray, use a standard airless sprayer 

(2 gallons/minute at 3,300 psi.) with a .029-.033 tip 

according to fan width spread of application and pump 

pressure. To achieve proper thickness, temperature and 

humidity must be considered by applicator. 

• NOTE: The number of applications and the 

thickness of each should be in accordance with the 

job specifications. 

• NOTE: All filters should be removed from both the 

gun handle and spray machine prior to application, 

as they will trap the ceramics. 

• NOTE: Temperatures must always be a minimum of 

5 degrees above the dew point during application. 

• NOTE: If SUPER THERM® is applied during a 

period of extremely high humidity or if there is rain 

soon after the application, bubbles may appear on 

the surface. Do not puncture these bubbles. This is 

normal and the coating will continue to cure with no 

effect on the performance or appearance of the 

coating. Bubbles will dry down tight and disappear 

without a trace or imprint. 

• NOTE: 2" corrugation = roof size x 135%; 2.5" 

corrugation = roof size x 145%; 3" corrugation = roof 

size x 160% 

MINIMUM SPREAD RATES (mil thickness) 

SUPER THERM® will be applied at no less than a total of 17 

mils wet (425 microns)/10.1 mils dry (250 microns) for each 

application. Spread Rate is 95 sq ft per gallon. (8.8 sq meter 

per gallon) 

CURE TIME 

1) 30-60 minutes to tack free at 70°F (21°C) 

2) Overcoat: 2 hours when 70°F (21 °C) at 40% Relative 

Humidity 

3) Full Cure: 21 days 

TEMPERATURE 

1) Apply between 40°F. and 150°F. 

2) Store between 40°F. and 100°F. 

CLEAN-UP EQUIPMENT 

1) After completion. spray system should be cleaned with 

soap and water; cleaned brushes and rollers can be 

reused. 

Superior Products International II, Inc.• 10835 W. 78th Street• Shawnee, KS 66214 

Website: www.spi~oating~.com • Email: sales@s_Qicoatings.com 

Case 2:20-cv-02366 Document 1-2 Filed 07/28/20 Page 3 of 5 

Exhibit A
SAFETY DATA SHEET (ST/I 1/00) pg 1 of2 

SECTION I - IDENTIFICATION OF THE PRODUCT AND THE COMPANY: 

PRODUCT NAME: Super Therm (UPC#851207002003, SKU#768399, Part#031 l) 

GHS PRODUCT IDENTIFIED: Global Harmonized System #3209.10.000 

CHEMICAL TYPE: Waterbased coating 

MANUFACTURER: Superior Products International II, Inc. 

ADDRESS: 10835 W. 78th St., Shawnee, KS 66214 USA 

PRODUCT USE: Insulation coating to create thermal barrier on substrates 

EMERGENCY TELEPHONE NUMBER: 800/424-9300; 202/483-7616 

SECTION II - HAZARD IDENTIFICATION: 

This product is water-based and not classified as dangerous for supply or conveyance. The ingredients are water-reduceable. This product has been analyzed for 

use in and around food manufacturing and found to be safe for use on non-contact surfaces. No toxics nor toxic off-gassing are present. 

SECTION III - HAZARD INGREDIENTS: 

Hazardous Ingredients % CAS/PIN LD-50 (species/route} LC50 (species} 

texanol 0.5 25265-77-4 3200 mg/kg {oral, rat) NAV 

mica/additives 14.0 12001-26-2 NAV NAV 

This material does not pose a potential risk of inhalation in the solution mixture contained herein. 

waterborne 

polyurethane 10.0 58043-05-3 NAV NAV 

SECTION IV - FIRST AID MEASURES: 

EYES: Flush with water for at least 15 minutes; consult physician if irritation 

continues. 

INGESTION: Do not induce vomiting. Drink 1-2 glasses milk/water. Seek 

medical attention according to amount of product ingested. 

SKIN: Wash with mild soap and water. 

INHALATION: Remove to fresh air. 

SECTION V ·FIREFIGHTING MEASURES: 

CONDITIONS OF FLAMMABILITY: Not flammable; water-based product 

HAZARDOUS COMBUSTION PRODUCTS: Carbon monoxide, methacrylate and 

other noxious gases 

AUTOIGNITION TEMP.: NAP MINIMUM IGNITION ENERGY: NAV 

FLAMMABLE LIMITS: (Lower) NAP% (Upper) NAP% FIRE POINT: NAV 

FLASH POINT & METHOD: NAP SENSITIVITY TO MECHANICAL IMPACT? No 

SENSITIVITY TO STATIC DISCHARGE? No 

SPECIAL PROCEDURES: Firefighters should wear full-body protection & SCBA 

MEANS OF EXTINCTION: Water, water fog, dry chemical, foam or CO2 

SECTION VI - ACCIDENTAL RELEASE MEASURES: 

Use kitty litter, sand or other to control spread and absorb liquid. 

SECTION VII - HANDLING AND STORAGE: 

STORAGE REQUIREMENTS: Keep from freezing. Store below SOC. degrees. Keep 

container closed tightly to prevent drying out. 

HANDLING PROCEDURES/EQUIPMENT: Treat as paint product. Use ventilation 

and protective equipment to suit conditions of use. Use soap and water for 

clean-up. 

NAP = Not Applicable NA V = Not Available 

Case 2:20-cv-02366 Document 1-2 Filed 07/28/20 Page 4 of 5 

Exhibit A
PRODUCT NAME: Super Therm pg 2 of2 

SECTIONVIII-EXPOSURECONTROLSANDPERSONALPROTECTION: 

PERSONAL PROTECTlVE EQUIPMENT; Avoid inhalation of liquid when applying. Use 

particulate respirator. 

ENGINEERING CONTROLS: Use mechanical ventilation to control aerosol or mist if 

product is sprayed. 

SECTION IX-PHYSICAL AND CHEMICAL PROPERTIES: 

PHYSlCALSTATE: Liquid SOLUBILITY IN WATER: soluble/miscible 

APPEARANCE AND ODOR: white color, mild acrylic odor 

FREEZING POINT: 30F. degrees BOILING POINT: 192C degrees pH: 8 

SPECIFlCGRA VITY: 1.4 ODOR THRESHOLD: 0.08-25ppm 

COEFF. WATER/OIL: NAY VAPOUR PRESSURE: 17 mmHg@ 20C degrees 

VAPOUR DENSITY (Air= 1): 2.1 

EVAPORATION RA TE: slow% VOLATILES:less than 5 

SECTION X-ST ABILITY AND REACTIVITY DATA: 

CONDITIONS OF REACTIVITY: stable CONDITIONS OF INSTABlLITY: stable 

CHEMICAL INCOMPATIBILITY: strong acids or bases CORROSlVEBEHAVlOR? no 

HAZARDOUS DECOMPOSITION PRODUCTS: none known, no hazardous polymerization 

SECTION XI-TOXICOLOGICAL PROPERTIES: 

ROUTESOFENTRY:SKINCONTACT SKINABSORPTION EYECONTACT X 

INHALA TJON INGESTION X SYNERGISTIC PRODUCTS None Known -- EXPOSURE LIMITS: mica 3 mg/m3 (ACGIH) 

EFFECTS OF ACUTE EXPOSURE: liquid splash could result in eye or nose irritations 

and/or headache 

EFFECTS OF CHRONIC EXPOSURE: excessive exposure to liquid product may result 

in minor irritations 

MUTAGENICITY: NAP 

REPRODUCTIVE TOXICITY: NAP 

TERA TOGENICITY: NAP 

CARCINOGENICITY: ingredients not listed 

SENSITIZATlON: not expected 

IRRlT ANCY: possible skin or eye irritation if not washed off 

SECTION XII-ENVIRONMENT AL INFORMATION: 

Air -this product is environmentally-friendly and poses no threat to the air. 

Water -the resins will be diluted and dissipate when flushed with water. 

Soil -the resin contents are biogradeable in ground acids over a period of time. 

No ecological hazards are known to exist. 

SE CTI ON XIII -WASTE DISPOSAL: 

Product spill should be contained by previously described absorption methods, and 

dried product disposed of as normal industrial waste according to all federal, state or 

governmental regulations. 

SECTIONXIV-TRANSPORTINFORMATION: 

The only restriction to carriage is for protection against freezing. Contents are water-based. 

SECTION XV-REGULATORY INFORMATION: 

Regulatory agency controls and restrictions are minimal regarding conveyance or use 

of water-based products other than what has been specifically addressed. 

SECTION XVI-OTHERINFORMA TION: 

••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••• 

PREPARED BY: J. Pritchett, Superior Products Int'! II, Inc. DATE: 9/11/ 18 

Case 2:20-cv-02366 Document 1-2 Filed 07/28/20 Page 5 of 5 

Exhibit A
 

Case 2:20-cv-02366 Document 1-3 Filed 07/28/20 Page 1 of 7 

EXHIBIT B 
SUPER Therm®

International Test Listings and Approvals

MEETS THE HIGHEST STANDARDS

SUPER THERM® has been rigorously field tested and meets the highest standards. The unique formula is UL, FM, ABS,

IMO and Coast Guard approved and a VOC Compliant water-based coating. SUPER THERM® has a Class A Fire Rating

against flame and smoke. Plus, it is USDA approved for use in and around food preparation areas. 

SUPER THERM® outperforms tra d itional insulation. It counters all three forms of heat ra d iation, convection and

c o n d u c t i o n . Traditional insulation only controls conduction. Experience the insulating power of SUPER THERM®.

Tests prove it.

SUPER THERM® is

the better option.

SOLAR REFLECTANCE TEST AFTER 15 YEARS

In Japan, university testing was performed on twenty one reflective coating in the market. Their average beginning reflectivity was 80%. After 591 days (1.5 years), reflectivity was reduced to 58%. This is an accurate view of most all reflective coatings

in the world market.

SUPER THERM®’s solar reflectivity at the new stage was 92.2%, so the reduction in 15 years was less than 20%. (92.2-73=19.2)

This result proves that SUPER THERM®’s durability in reflectivity is by far excellent.

SUPER THERM®’s solar reflectance after 15 years was 73%. The reduction of solar reflectance in 3 years tested for the Energy

Star Program by the EPA was only 0.01%.

The test piece was taken from

a roof in January 2006 where

SUPER THERM® was applied in

1989, and tested at Building

Material Test Center in Japan.

The climate is very severe in this

area with 38° C (100° F) in the

summer, sand storms, very

strong sun radiation, and -21° C

(-5° F) in the winter with snow

and ice.

The reflectance of near infrared

is 67.1%, but this is because

the SUPER THERM® at that

time did not contain the fourth

ceramic, which was introduced

in 2000 and designed to block

infrared rays. Therefore, the

result with the current SUPER

THERM® will be better.
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Challenge: No other insulation or weatherization material in the market has the facts, tests results and field studies to compare 

with SUPER THERM®. There is no product in the world market with the proof of performance equal to SUPER THERM®. Forget 

the pretty brochures and advertising media and look at the facts to see the real value of SUPER THERM®. 

1.H i gh Re f l ectiv ity of Ra d i ation He at 

Tran s fe r (sum of all three ra d iat i o n 

waves) is 95% to bl ock the loading of heat 

onto the surface. 

a. UV re p res en t s 3% o f he a t lo ad 

S U PE R THERM blocks 99% of hea t 

generated by UV. 

b. Visual Light (short wave ra d iat i o n ) 

re p resents 40% of heat load-S U PER 

THERM blocks 92% of heat genera te d 

by Visual Light. 

c . I n f ra red (long wave ra d iat i o n ) 

re p resents 57% of heat load-S U PER 

THERM blocks 99% of heat genera te d 

by Infrared. 

2. H i gh Th e r ma l Emm it an c e to 

t h row off heat that has loaded onto 

it ’s surface. S U PE R THERM has a 

thermal emittance of 0.91. 

R E G I S T R ATIONS AND CERT I F I C AT I O N S : 

3. A m e r ic an Bu re au of Shipping (ABS) 

a. Passed SOLAS 1974 (as amended) 

re q u i rements for paints/finish 

m ate r ials requiring compliance wit h 

Pa rts 2 (Smoke & Tox ic ity) and 5 

(Surface Flammability) of the IMO FTP 

Code, Res.MSC.61(67). 

b. U.S. Ty pe Ap p ro val Ce rt i f ic ate 

No. SL520997-a 

c . E. C. Ty pe Ap p ro val Ce rt i f ic ate 

No. 04-CH 468315-MED1 

d. U.S. Coast Guard Product Approval 

No. 164.112/EC1347/4368315/EC0729 

4. Energy Star Program 

Ap p roved Pa rtner/ Ap p roved Prod u c t 

a. O n ly 0.6% drop in re f l e c t iv ity over a 

3 year roof te st pe r i od (2% over 10 years). 

5. I CC (Inte r national Code Council) 

BOCA Legacy Report. 

6 . USDA (Un ited States Dept. of Ag r ic ult u re ) 

a. USDA approved product for use 

inside food facilities. 

7. Marine App rovals of Wo r l d - w i d e 

Sa lt Water and Ma r itime Us e 

a. DNV (Det Norske Veritas) 

8 .Fa ctory Mutual App rova l 

a. Te sted and approved for Me tal Roo f i n g 

9. GSA App roval for Fed e ral Us e s 

10 . UL (Un d e r w r iters Labo rato r y, Inc.) 

approval 

11. ECAP Re po rt: Energy Con s e r vation 

A s s i stance Prog ra m D e p a rt m e nt of 

E n e rg y -Un ited States of Americ a -

Florida Energy Office 

12 . S tate of Ca l i fornia Co ol Ro of Prog ra m 

a. Approved and listed 

13. S tate of Ca l i fornia Bu re au of Hom e 

Furnishings and Th e r mal Insulation 

a. License Number TE 1392 

14.S tate of Flo r i da Energy Re b ate 

Program 

a. Qualifies for a pe rc e n ta ge re d u c t i o n 

f rom cost of coating subst rate s 

15. Su pe r ior Pro d u cts Inte r national II, 

Inc. is an active member of the NRCA 

( National Ro ofing Cont ra ctors Assoc) 

16. A S T M T E S T L I S T I N G S : 

a. B117/D 1654 Salt Fog (400 hours and 

2000 hours)–passed 

b . C 2 3 6 - 8 9 ( 9 3 ) T h e r m a l 

Tr a n s m i t t a n c e / C o n d u c t a n c e 

i. Fiberglass 0.52 K 

i i . SUPER THERM in one coat 0.31 K 

i i i . SUPER THERM in two coats 0.21 K 

c . C 411 High -Te m pe rat u re Su r fa c e 

Performance 

20th Century Insulation Theory: “R” 

value – load heat and then resist heat 

transfer through the material. 

21th Century Insulation Theory : 

BLOCK HEAT LOAD. Prevent heat load 

into the surface to reduce heat that is 

available for transfer. 

d. C 412 Tensile Pro pe rt i e s–444 psi 

e. D 522 Ma n d rel Bend on metal or 

rubber materials 

f. D 1653 Water Va por Pe r m e ab i l ity 3% 

g. D 3273-82T/ D3274 Fu n gal Re s i sta n c e 

h .D 4 0 6 0 Ab ra s io n Re s i sta n c e 

i . E 84/NFPA 255/ U L 723/ U BC 42-

1/ANSI2.5/FM E 84 – Flame Spread / 

Smoke–“0” Class A or 1 

j. E 84-89 Flame spread/ Smoke 

De v e l o p m e n t–Flame “0” and Smoke “0” 

k. E 96 Water Va por Tra n s m i s s i o n – 

Less than .01 

l . E 108 Flame Spread on Pitched Roo f 

–passed 

m .E 9 03-96 Spe c t ral Re f l e c tance 80 % 

and 0.6% loss after three ye a r s 

weathering. 

n . E 12 69 He at Ca p a c ity by Diffe re n t ia l 

Scanning Colorimeter 

o. E 1461 (92) Th e r m a l D i f f u s iv ity/ 

C o n d u c t iv ity by Flash Me t h od – re d u c e d 

367.20 BTU conduction to 3.99 

p. G 53 1000 hours UV Ex po s e d 

q. D 7088 (Su perseded Fe d e ral 

S pe c i f ic ation TT- P-1411A Paint) hydro -

stat ic pre s s u re re s i stance of a submit te d 

water proof coating over concre te inte r i o r 

s u r face to prevent ex terior rain driv e n 

water from pe n e t rating the wall fro m 

ex terior to interior during const r u c t i o n . 

r. D 6904 re s i stance to wind driven ra i n 

for ex terior coatings applied to masonry 

w ithout bl ock filler in te st bl oc k s . 

Su perseded Fe d e ral Spe c i f ic ation TT-C -

555 B. S U PER THERM is a ce r t ified wa ter 

barrier. 

s . D-3274 numerical basis for rating the 

d eg ree of fungal growth or mold and dirt 

a c c u m u l ation on paint films. Re s i st the 

development of mold and mildew and 

not allow the growth over it ’s surfa c e . 

Score 9 out of 10. 

t. E90 Sta n d a rd Me t h od for Labo rato r y 

Me a s u rement of Airborne Sound 

Transmission Loss of Building Pa rt it i o n s 

u . E 413 Sta n d a rd Classific ation for 

De te r m i n ation of Sound Tra n s m i s s i o n 

C l a s s . 

17. NASA (National Ae ronau tics and 

Space Ad m i n i st ration) Te sti n g : 

a. N ASA 8060 .1B/C Te st 1 Flammab i l it y 

test, Class A , “0” Flame Spread 

b. N ASA 8060 .1C Te st 7 Tox ic Of fgassing Te st, K ra ted (no of f-ga s s i n g ) . 

18 . ABS (Americ an Bu re au of 

S h i pping), IMO (Inte r nationa l 

Ma r i n e Organization), and US Coast 

Guard Approval: 

a. IMO A. 653 (16) Flame Spre a d– p a s s e d 

b. MSC 41 Smoke Tox ic it y– p a s s e d 

19. Jap anese Te sti n g ( Jap anese Instit u te 

of Technology): 

a. JIS A 5759 Re f l e c t iv ity Light and 

Radiation 

i. Vi s u a l L i gh t Rat i o n– 92 . 2 % 

i i . Long Wave Ra d iation (Infra re d ) – 99.5 % 

20 . C h i na Ce nter for Tech n ical Te sti n g : 

a. Nat iona l Me a s u remen t M0729 

b. GB/T 1771-91 Re s i stance to Sa lt Fo g 

(2000 hours)–passed 

c . GB/T 1866-88 Manual Ag i n g 

(2000 hours)–passed 

d. GB/T 10834 -88 Re s i stance to Sa lt 

Water (1000 hours)–passed 

e. GB/T 5219-85 Adhesion (pulling 

apart method) – 4.07 MPa 

f. GB/T 1733.93 Boiling Wate r 

Immersion (8 hours)–passed 

Exhibit B
1.H i gh Re f l ectiv ity of Ra d i ation He at

Tran s fe r (sum of all three ra d iat i o n

waves) is 95% to bl ock the loading of heat

onto the surface.

a. UV re p res en t s 3% o f he a t lo ad

S U PE R THERM blocks 99% of hea t

generated by UV.

b. Visual Light (short wave ra d iat i o n )

re p resents 40% of heat load-S U PER

THERM blocks 92% of heat genera te d

by Visual Light.

c . I n f ra red (long wave ra d iat i o n )

re p resents 57% of heat load-S U PER

THERM blocks 99% of heat genera te d

by Infrared.

2. H i gh Th e r ma l Emm it an c e to

t h row off heat that has loaded onto

it ’s surface. S U PE R THERM has a

thermal emittance of 0.91.

R E G I S T R ATIONS AND CERT I F I C AT I O N S :

3. A m e r ic an Bu re au of Shipping (ABS)

a. Passed SOLAS 1974 (as amended)

re q u i rements for paints/finish

m ate r ials requiring compliance wit h

Pa rts 2 (Smoke & Tox ic ity) and 5

(Surface Flammability) of the IMO FTP

Code, Res.MSC.61(67).

b. U.S. Ty pe Ap p ro val Ce rt i f ic ate

No. SL520997-a

c . E. C. Ty pe Ap p ro val Ce rt i f ic ate

No. 04-CH 468315-MED1

d. U.S. Coast Guard Product Approval

No. 164.112/EC1347/4368315/EC0729

4.Energy Star Program

Ap p roved Pa rtner/ Ap p roved Prod u c t

a. O n ly 0.6% drop in re f l e c t iv ity over a

3 year roof te st pe r i od (2% over 10 years). 

5. I CC (Inte r national Code Council)

BOCA Legacy Report.

6 . USDA (Un ited States Dept. of Ag r ic ult u re )

a. USDA approved product for use

inside food facilities.

7. Marine App rovals of Wo r l d - w i d e

Sa lt Water and Ma r itime Us e

a. DNV (Det Norske Veritas)

8 .Fa ctory Mutual App rova l

a. Te sted and approved for Me tal Roo f i n g

9. GSA App roval for Fed e ral Us e s

UL (Un d e r w r iters Labo rato r y, Inc.)

approval

ECAP Re po rt: Energy Con s e r vation

A s s i stance Prog ra m D e p a rt m e nt of

E n e rg y -Un ited States of Americ a -

Florida Energy Office

12 . S tate of Ca l i fornia Co ol Ro of Prog ra m

a. Approved and listed

13. S tate of Ca l i fornia Bu re au of Hom e

Furnishings and Th e r mal Insulation

a. License Number TE 1392

14.S tate of Flo r i da Energy Re b ate

Program

a. Qualifies for a pe rc e n ta ge re d u c t i o n

f rom cost of coating subst rate s

15. Su pe r ior Pro d u cts Inte r national II,

Inc. is an active member of the NRCA 

( National Ro ofing Cont ra ctors Assoc)

16. A S T M T E S T L I S T I N G S :

a. B117/D 1654 Salt Fog (400 hours and

2000 hours)–passed

b . C 2 3 6 - 8 9 ( 9 3 ) T h e r m a l

Tr a n s m i t t a n c e / C o n d u c t a n c e

i. Fiberglass 0.52 K

i i . SUPER THERM in one coat 0.31 K

i i i .SUPER THERM in two coats 0.21 K

c . C 411 High -Te m pe rat u re Su r fa c e

Performance 

d.C 412 Tensile Pro pe rt i e s–444 psi

e. D 522 Ma n d rel Bend on metal or

rubber materials

f. D 1653 Water Va por Pe r m e ab i l ity 3%

g. D 3273-82T/ D3274 Fu n gal Re s i sta n c e

h .D 4 0 6 0 Ab ra s io n Re s i sta n c e

i . E 84/NFPA 255/ U L 723/ U BC 42-

1/ANSI2.5/FM E 84 – Flame Spread /

Smoke–“0” Class A or 1

j. E 84-89 Flame spread/ Smoke

De v e l o p m e n t–Flame “0” and Smoke “0”

k. E 96 Water Va por Tra n s m i s s i o n –

Less than .01

l . E 108 Flame Spread on Pitched Roo f

–passed

m .E 9 03-96 Spe c t ral Re f l e c tance 80 %

and 0.6% loss after three ye a r s

weathering.

n . E 12 69 He at Ca p a c ity by Diffe re n t ia l

Scanning Colorimeter

o. E 1461 (92) Th e r m a l D i f f u s iv ity/ 

C o n d u c t iv ity by Flash Me t h od – re d u c e d

367.20 BTU conduction to 3.99

p. G 53 1000 hours UV Ex po s e d

q. D 7088 (Su perseded Fe d e ral

S pe c i f ic ation TT- P-1411A Paint) hydro -

stat ic pre s s u re re s i stance of a submit te d

water proof coating over concre te inte r i o r

s u r face to prevent ex terior rain driv e n

water from pe n e t rating the wall fro m

ex terior to interior during const r u c t i o n .

r. D 6904 re s i stance to wind driven ra i n

for ex terior coatings applied to masonry

w ithout bl ock filler in te st bl oc k s .

Su perseded Fe d e ral Spe c i f ic ation TT-C -

555 B. S U PER THERM is a ce r t ified wa ter

barrier.

s . D-3274 numerical basis for rating the

d eg ree of fungal growth or mold and dirt

a c c u m u l ation on paint films. Re s i st the

development of mold and mildew and

not allow the growth over it ’s surfa c e .

Score 9 out of 10.

t. E90 Sta n d a rd Me t h od for Labo rato r y

Me a s u rement of Airborne Sound 

Transmission Loss of Building Pa rt it i o n s

u . E 413 Sta n d a rd Classific ation for

De te r m i n ation of Sound Tra n s m i s s i o n

C l a s s .

17. NASA (National Ae ronau tics and

Space Ad m i n i st ration) Te sti n g :

a. N ASA 8060 .1B/C Te st 1 Flammab i l it y

test, Class A , “0” Flame Spread

b. N ASA 8060 .1C Te st 7 Tox ic Of fgassing Te st, K ra ted (no of f-ga s s i n g ) .

18 . ABS (Americ an Bu re au of

S h i pping), IMO (Inte r nationa l

Ma r i n e Organization), and US Coast

Guard Approval:

a. IMO A. 653 (16) Flame Spre a d– p a s s e d

b. MSC 41 Smoke Tox ic it y– p a s s e d

19. Jap anese Te sti n g ( Jap anese Instit u te

of Technology):

a. JIS A 5759 Re f l e c t iv ity Light and

Radiation

i. Vi s u a l L i gh t Rat i o n– 92 . 2 %

i i . Long Wave Ra d iation (Infra re d ) – 99.5 %

20 . C h i na Ce nter for Tech n ical Te sti n g :

a. Nat iona l Me a s u remen t M0729

b. GB/T 1771-91 Re s i stance to Sa lt Fo g

(2000 hours)–passed

c . GB/T 1866-88 Manual Ag i n g

(2000 hours)–passed

d. GB/T 10834 -88 Re s i stance to Sa lt

Water (1000 hours)–passed

e. GB/T 5219-85 Adhesion (pulling 

apart method) – 4.07 MPa

f. GB/T 1733.93 Boiling Wate r

Immersion (8 hours)–passed

Challenge: No other insulation or weatherization material in the market has the facts, tests results and field studies to compare

with SUPER THERM®. There is no product in the world market with the proof of performance equal to SUPER THERM®. Forget

the pretty brochures and advertising media and look at the facts to see the real value of SUPER THERM®.

20th Century Insulation Theory: “R”

value – load heat and then resist heat

transfer through the material.

21th Century Insulation Theory :

BLOCK HEAT LOAD. Prevent heat load

into the surface to reduce heat that is

available for transfer.

10 .

11.

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 
1.H i gh Re f l ectiv ity of Ra d i ation He at

Tran s fe r (sum of all three ra d iat i o n

waves) is 95% to bl ock the loading of heat

onto the surface.

a. UV re p res en t s 3% o f he a t lo ad

S U PE R THERM blocks 99% of hea t

generated by UV.

b. Visual Light (short wave ra d iat i o n )

re p resents 40% of heat load-S U PER

THERM blocks 92% of heat genera te d

by Visual Light.

c . I n f ra red (long wave ra d iat i o n )

re p resents 57% of heat load-S U PER

THERM blocks 99% of heat genera te d

by Infrared.

2. H i gh Th e r ma l Emm it an c e to

t h row off heat that has loaded onto

it ’s surface. S U PE R THERM has a

thermal emittance of 0.91.

R E G I S T R ATIONS AND CERT I F I C AT I O N S :

3. A m e r ic an Bu re au of Shipping (ABS)

a. Passed SOLAS 1974 (as amended)

re q u i rements for paints/finish

m ate r ials requiring compliance wit h

Pa rts 2 (Smoke & Tox ic ity) and 5

(Surface Flammability) of the IMO FTP

Code, Res.MSC.61(67).

b. U.S. Ty pe Ap p ro val Ce rt i f ic ate

No. SL520997-a

c . E. C. Ty pe Ap p ro val Ce rt i f ic ate

No. 04-CH 468315-MED1

d. U.S. Coast Guard Product Approval

No. 164.112/EC1347/4368315/EC0729

4.Energy Star Program

Ap p roved Pa rtner/ Ap p roved Prod u c t

a. O n ly 0.6% drop in re f l e c t iv ity over a

3 year roof te st pe r i od (2% over 10 years). 

5. I CC (Inte r national Code Council)

BOCA Legacy Report.

6 . USDA (Un ited States Dept. of Ag r ic ult u re )

a. USDA approved product for use

inside food facilities.

7. Marine App rovals of Wo r l d - w i d e

Sa lt Water and Ma r itime Us e

a. DNV (Det Norske Veritas)

8 .Fa ctory Mutual App rova l

a. Te sted and approved for Me tal Roo f i n g

9. GSA App roval for Fed e ral Us e s

UL (Un d e r w r iters Labo rato r y, Inc.)

approval

ECAP Re po rt: Energy Con s e r vation

A s s i stance Prog ra m D e p a rt m e nt of

E n e rg y -Un ited States of Americ a -

Florida Energy Office

12 . S tate of Ca l i fornia Co ol Ro of Prog ra m

a. Approved and listed

13. S tate of Ca l i fornia Bu re au of Hom e

Furnishings and Th e r mal Insulation

a. License Number TE 1392

14.S tate of Flo r i da Energy Re b ate

Program

a. Qualifies for a pe rc e n ta ge re d u c t i o n

f rom cost of coating subst rate s

15. Su pe r ior Pro d u cts Inte r national II,

Inc. is an active member of the NRCA 

( National Ro ofing Cont ra ctors Assoc)

16. A S T M T E S T L I S T I N G S :

a. B117/D 1654 Salt Fog (400 hours and

2000 hours)–passed

b . C 2 3 6 - 8 9 ( 9 3 ) T h e r m a l

Tr a n s m i t t a n c e / C o n d u c t a n c e

i. Fiberglass 0.52 K

i i . SUPER THERM in one coat 0.31 K

i i i .SUPER THERM in two coats 0.21 K

c . C 411 High -Te m pe rat u re Su r fa c e

Performance 

d.C 412 Tensile Pro pe rt i e s–444 psi

e. D 522 Ma n d rel Bend on metal or

rubber materials

f. D 1653 Water Va por Pe r m e ab i l ity 3%

g. D 3273-82T/ D3274 Fu n gal Re s i sta n c e

h .D 4 0 6 0 Ab ra s io n Re s i sta n c e

i . E 84/NFPA 255/ U L 723/ U BC 42-

1/ANSI2.5/FM E 84 – Flame Spread /

Smoke–“0” Class A or 1

j. E 84-89 Flame spread/ Smoke

De v e l o p m e n t–Flame “0” and Smoke “0”

k. E 96 Water Va por Tra n s m i s s i o n –

Less than .01

l . E 108 Flame Spread on Pitched Roo f

–passed

m .E 9 03-96 Spe c t ral Re f l e c tance 80 %

and 0.6% loss after three ye a r s

weathering.

n . E 12 69 He at Ca p a c ity by Diffe re n t ia l

Scanning Colorimeter

o. E 1461 (92) Th e r m a l D i f f u s iv ity/ 

C o n d u c t iv ity by Flash Me t h od – re d u c e d

367.20 BTU conduction to 3.99

p. G 53 1000 hours UV Ex po s e d

q. D 7088 (Su perseded Fe d e ral

S pe c i f ic ation TT- P-1411A Paint) hydro -

stat ic pre s s u re re s i stance of a submit te d

water proof coating over concre te inte r i o r

s u r face to prevent ex terior rain driv e n

water from pe n e t rating the wall fro m

ex terior to interior during const r u c t i o n .

r. D 6904 re s i stance to wind driven ra i n

for ex terior coatings applied to masonry

w ithout bl ock filler in te st bl oc k s .

Su perseded Fe d e ral Spe c i f ic ation TT-C -

555 B. S U PER THERM is a ce r t ified wa ter

barrier.

s . D-3274 numerical basis for rating the

d eg ree of fungal growth or mold and dirt

a c c u m u l ation on paint films. Re s i st the

development of mold and mildew and

not allow the growth over it ’s surfa c e .

Score 9 out of 10.

t. E90 Sta n d a rd Me t h od for Labo rato r y

Me a s u rement of Airborne Sound 

Transmission Loss of Building Pa rt it i o n s

u . E 413 Sta n d a rd Classific ation for

De te r m i n ation of Sound Tra n s m i s s i o n

C l a s s .

17. NASA (National Ae ronau tics and

Space Ad m i n i st ration) Te sti n g :

a. N ASA 8060 .1B/C Te st 1 Flammab i l it y

test, Class A , “0” Flame Spread

b. N ASA 8060 .1C Te st 7 Tox ic Of fgassing Te st, K ra ted (no of f-ga s s i n g ) .

18 . ABS (Americ an Bu re au of

S h i pping), IMO (Inte r nationa l

Ma r i n e Organization), and US Coast

Guard Approval:

a. IMO A. 653 (16) Flame Spre a d– p a s s e d

b. MSC 41 Smoke Tox ic it y– p a s s e d

19. Jap anese Te sti n g ( Jap anese Instit u te

of Technology):

a. JIS A 5759 Re f l e c t iv ity Light and

Radiation

i. Vi s u a l L i gh t Rat i o n– 92 . 2 %

i i . Long Wave Ra d iation (Infra re d ) – 99.5 %

20 . C h i na Ce nter for Tech n ical Te sti n g :

a. Nat iona l Me a s u remen t M0729

b. GB/T 1771-91 Re s i stance to Sa lt Fo g

(2000 hours)–passed

c . GB/T 1866-88 Manual Ag i n g

(2000 hours)–passed

d. GB/T 10834 -88 Re s i stance to Sa lt

Water (1000 hours)–passed

e. GB/T 5219-85 Adhesion (pulling 

apart method) – 4.07 MPa

f. GB/T 1733.93 Boiling Wate r

Immersion (8 hours)–passed

Challenge: No other insulation or weatherization material in the market has the facts, tests results and field studies to compare

with SUPER THERM®. There is no product in the world market with the proof of performance equal to SUPER THERM®. Forget

the pretty brochures and advertising media and look at the facts to see the real value of SUPER THERM®.

20th Century Insulation Theory: “R”

value – load heat and then resist heat

transfer through the material.

21th Century Insulation Theory :

BLOCK HEAT LOAD. Prevent heat load

into the surface to reduce heat that is

available for transfer.

10 .

11.

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 
I l'X")'1⁄4 

:'? 

::=,::J 

?O 

w 

5(1 

4\'.J 

?>J 

3) 

[,J ---- -- ---:_J--

I) 

0 

Wave Length (nm) 

lfflnpsa[OO! II! <Xl!iings & cttll!C lllllilrill5 11 IIUnliQ ht ✓ 

6) 

1t::o:)'.J 

..:o,..... , ........... 11.•. ~1-- - , 

Z9JC•; 

SUPER Therm® 

International Test Listings and Approvals 

MEETS THE HIGHEST STANDARDS 

SUPER THERM® has been rigorously field tested and meets the highest standards. The unique formula is UL, FM, ABS, 

IMO and Coast Guard approved and a VOC Compliant water-based coating. SUPER THERM® has a Class A Fire Rating 

against flame and smoke. Plus, it is USDA approved for use in and around food preparation areas. 

SUPER THERM® outperforms tra d itional insulation. It counters all three forms of heat ra d iation, convection and 

c o n d u c t i o n . Traditional insulation only controls conduction. Experience the insulating power of SUPER THERM®. 

SOLAR REFLECTANCE TEST AFTER 15 YEARS 

The test piece was taken from 

a roof in January 2006 where 

SUPER THERM® was applied in 

1989, and tested at Building 

Material Test Center in Japan. 

The climate is very severe in this 

area with 38° C (100° F) in the 

summer, sand storms, very 

strong sun radiation, and -21° C 

(-5° F) in the winter with snow 

and ice. 

The reflectance of near infrared 

is 67.1%, but this is because 

the SUPER THERM® at that 

time did not contain the fourth 

ceramic, which was introduced 

in 2000 and designed to block 

infrared rays. Therefore, the 

result with the current SUPER 

THERM® will be better. 

In Japan, university testing was performed on twenty one reflective coating in the market. Their average beginning reflectivity was 80%. After 591 days (1.5 years), reflectivity was reduced to 58%. This is an accurate view of most all reflective coatings 

in the world market. 

SUPER THERM®’s solar reflectivity at the new stage was 92.2%, so the reduction in 15 years was less than 20%. (92.2-73=19.2) 

This result proves that SUPER THERM®’s durability in reflectivity is by far excellent. 

SUPER THERM®’s solar reflectance after 15 years was 73%. The reduction of solar reflectance in 3 years tested for the Energy 

Star Program by the EPA was only 0.01%. 

Tests prove it. 

SUPER THERM® is 

the better option. 

Exhibit B
SUPER Therm®

International Test Listings and Approvals

MEETS THE HIGHEST STANDARDS

SUPER THERM® has been rigorously field tested and meets the highest standards. The unique formula is UL, FM, ABS,

IMO and Coast Guard approved and a VOC Compliant water-based coating. SUPER THERM® has a Class A Fire Rating

against flame and smoke. Plus, it is USDA approved for use in and around food preparation areas. 

SUPER THERM® outperforms tra d itional insulation. It counters all three forms of heat ra d iation, convection and

c o n d u c t i o n . Traditional insulation only controls conduction. Experience the insulating power of SUPER THERM®.

Tests prove it.

SUPER THERM® is

the better option.

SOLAR REFLECTANCE TEST AFTER 15 YEARS

In Japan, university testing was performed on twenty one reflective coating in the market. Their average beginning reflectivity was 80%. After 591 days (1.5 years), reflectivity was reduced to 58%. This is an accurate view of most all reflective coatings

in the world market.

SUPER THERM®’s solar reflectivity at the new stage was 92.2%, so the reduction in 15 years was less than 20%. (92.2-73=19.2)

This result proves that SUPER THERM®’s durability in reflectivity is by far excellent.

SUPER THERM®’s solar reflectance after 15 years was 73%. The reduction of solar reflectance in 3 years tested for the Energy

Star Program by the EPA was only 0.01%.

The test piece was taken from

a roof in January 2006 where

SUPER THERM® was applied in

1989, and tested at Building

Material Test Center in Japan.

The climate is very severe in this

area with 38° C (100° F) in the

summer, sand storms, very

strong sun radiation, and -21° C

(-5° F) in the winter with snow

and ice.

The reflectance of near infrared

is 67.1%, but this is because

the SUPER THERM® at that

time did not contain the fourth

ceramic, which was introduced

in 2000 and designed to block

infrared rays. Therefore, the

result with the current SUPER

THERM® will be better. 
 

Case 2:20-cv-02366 Document 1-4 Filed 07/28/20 Page 1 of 5 

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Case 2:20-cv-02366 Document 1-5 Filed 07/28/20 Page 1 of 7 

EXHIBIT D 
e 2:20-cv-02366 Document 1-5 Filed 07/28/20 Page 2 

SUPER THERM®

Protecting industries with premium coatings 

Achieve optimum cooling with a coating that blocks and repels radiational heat. 

Exhibit D
 

e 2:20-cv-02366 

Super Therm® 

Experience Innovative Insulation 

Document 1-5 Filed 07/28/20 Page 3 

Heat Blocking, 

Not Refl ection 

The measurement of how fast 

heat loads or is absorbed and then 

the speed at which it transfers 

through the material is called 

the “R” value. This resistance 

 factor slows but does not prevent 

the heat load and transfer. 

This is why these materials 

“must have more thickness” 

to provide any beneft. 

When it comes to extreme 

temperatures, Super Therm® 

redefi nes the science behind 

insulation and weatherization. 

Super Therm® features a blend 

of ceramic compounds that 

will reflect radiational heat 

away from protected areas 

when applied to a surface. 

By allowing only 5% heat 

load on the surface facing 

the radiational heat source, 

Super Therm® achieves 

innovative heat refl ection. 

These core properties of Super 

Therm® continue to attract 

industries needing premium 

insulation solutions that yield 

cost-saving, long-term energy 

effi ciencies. From marine 

and aviation to oil and gas, 

transportation, and residential, 

Super Therm® is being accepted 

and applied by the most 

competitive industries in the 

world. This widespread use 

is just one more way that SPI 

Coatings remain an obvious 

and trusted choice for real 

world coating solutions. 

■ 99% Infrared 

■ Visual Light 

■ Ultra Violet 

Super Therm® does not 

absorb solar heat and does 

not require thickness — 

effectively eliminating a 

measurement of (R) value. 

Super Therm® has four (4) 

ceramic compounds. Three 

of these compounds match 

the wave size of each of the 

solar radiation waves to block 

the heat load. The fourth 

ceramic has such low density 

that the heat cannot load into 

the surface of Super Therm® 

and therefore cannot be 

absorbed and transferred. 

This is why the surface of 

Super Therm® is not likely 

to be more than 2-10 degrees F 

over ambient air temperature 

in any climate. If heat 

load is blocked, there is no 

heat to be absorbed and 

transferred even when the 

surface becomes dirty. Field 

documentation shows no 

change in the performance 

of Super Therm® after 10 

years, and only an 8% drop 

in blocking heat load after 

15 years. 

Superior Products International II, Inc. spicoatings.com 

Exhibit D
 

e 2:20-cv-02366 

Super Therm® passed 

NASA testing with 

Best Test Result. 

Document 1-5 Filed 07/28/20 Page 4 

SUPER THERM® VS. TRADITIONAL INSULATION 

Super Therm® 

Super Therm® has a blend of four unique 

low-density ceramics that repel solar 

radiational heat by matching/blocking heat 

waves. Super Therm® resists the loading 

of surface heat over the envelope of a 

building to stop heat load before 

it starts. Traditional insulation 

ignores heat transfer through 

radiation and convection and 

does not repel heat produced 

by the full spectrum of sunlight. With Super 

Therm®, you can combat visual, ultraviolet 

and infrared light to block 95% of radiational 

heat load. 

Super Therm® advantages 

over traditional insulation: 

• Combats convection, conduction 

and radiation 

• Repels heat through refl ection 

• More than 20 years of life expectancy 

• Designed and tested under extreme 

temperatures (minus 60° to plus 140° F 

ambient air temperature) 

A Comparison of Popular 

Insulation Options 

• Ease of installation 

• Blocks humidity and wind-driven rain 

• Blocks wind and air infi ltration 

Traditional Insulation 

Insulations such as cellulose, fi berglass, 

rock wool and polystyrene foam have 

remained unchanged for 50 years. These 

types of insulations allow 100% heat load 

and absorption and only slow conduction 

or heat transfer with small pockets of air. 

All are affected by moisture absorption 

which kills effective resistance. These 

inefficiencies are where Super Therm® 

presents innovative solutions for industries. 

Disadvantages of traditional insulation: 

• Combats only conductive heat 

• No capability to repel heat 

• Affected by moisture and air infi ltration 

• Designed and tested only for 75 ̊F 

for the “R” value 

• Loses thickness when compacted 

into space upon installation 

• Positioned between building studs 

• Causes corrosion under insulation 

Superior Products International II, Inc. spicoatings.com 

Exhibit D
__ ..._ _,... __ 

..... _ -­... ,... 

--

----:.-:: ::1:--

e 2:20-cv-02366 Document 1-5 Filed 07/28/20 

Temperature of coatings and 

other materials in sunlight 

THERMAL STUDY 

JUAYMAH NGL SPHEROID TANKS 

Super Therm® Existing Tank 

NG Tank Spheroid 203A NG Tank Spheroid 203B 

Saudi Aramco – November 2013 

Page 5 

SUPER THERM® IN USE TODAY 

Aviation 

Tucson International Airport 

Arizona, U.S. 

22% overall energy reduction 

with 40% HVAC savings 

Oil and Gas 

Mitsubishi Oil Terminal 

Osaka, Japan 

Reduced evaporation of f nished 

petrochemicals 

Marine 

Blue Chip Casino Ship 

Indiana, U.S. 

Offshore 

GDF Suez 

North Sea, U.K. 

Residential 

Residential Neighborhood 

Arizona, U.S. 

Super Therm® provides sound 

dampening and color options 

Transportation 

Pacifi c Shipping 

and Trucking 

Telecommunications 

Vodaphone Group PLC 

Tourism 

Address Hotel 

Dubai, U.A.E. 

52°C roof temperature before 

application, 42°C after completion 

PROVEN ENERGY 

EFFICIENCY 

Surface Temperature 

Performance 

U.S. Department of Energy 

• Surface conduction related 

to energy loads was reduced 

46-52% 

• Exterior surface temperature 

47 ̊F degrees cooler 

Interior Temperature 

Performance 

U.S. Department of Energy 

• Super Therm® out-performed 

white paint 

• 26% - 30% increase 

in energy effi ciency 

INDUSTRY COMPLIANT 

AND TRUSTED 

• U.S. Green Building Certifi ed 

• MASDAR certifi cation 

in UAE 

• VOC compliant 

• Class “A” Fire Rating 

• DNV and ABS Approved 

• USDA Approved 

Exhibit D
 

 

e 2:20-cv-02366 

PROTECTING INDUSTRIES WITH PREMIUM COATINGS 

Document 1-5 Filed 07/28/20 Page 6 

40 to 60% of total 

building energy costs 

directly relate to air 

conditioning expense. 

Beat the heat build-up 

with Super Therm® . 

Industries cannot rely on 

temporary effi ciencies when 

delivering their products and 

systems. That’s why SPI 

Coatings have been selected 

by numerous corporations and 

individuals. Our coatings are 

designed to save you money PCT Reflectance 

because of their innovative 

performance and long-term 

durability. With an international 

presence in a wide diversity of 

markets, SPI continues to bring 

industries peace of mind when 

it comes to combating high 

energy costs and corrosion. 

TIME TESTED SOLAR 

REFLECTIVITY 

Super Therm® has the ability to endure severe conditions 

for extended time periods making it an effi cient solution 

for a wide variety of industries. The results below reveal 

the tested effectiveness of Super Therm® after 15 years 

of performance. 

Super Therm® Solar Energy Refl ectance Chart 

250 750 1250 1750 2250 

100% 

90 

80 

70 

60 

50 

40 

30 

20 

10 

0 Total Solar Reflectance = 96.01% 

Wavelength (nm) 

In this study, the solar refectance of Super Therm® after 

15 years stood at 84%. By comparison, university testing 

in Japan was performed on 21 insulation coatings in the 

market. Their average beginning refectivity was 80% and 

after 1.5 years their refectivity was reduced to 58%. This 

sampling represents the clear advantage Super Therm® 

brings to the market for industries needing consistent and 

cost-effective thermal protection. 

As operational problems 

become more complex, 

SPI keeps pushing the 

boundaries of effectiveness. 

It’s a system of products refi ned 

from remarkably conclusive 

data and forged under the most 

rigorous conditions. 

TOP COMPANIES USING 

SUPER THERM® 

• Mitsubishi 

• Nissan 

• Panasonic 

• General Dynamics 

• Hoover Dam 

• HEB Grocery Company 

• Trucking - Refrigeration Trailers 

• Major Oil Firms - Worldwide 

• Halliburton Company 

• Drydocks World 

• Vodafone Group PLC 

• Home Builders 

• U.S. Army 

• U.S. Air Force 

• U.S. Navy 

Certifed Environmentally Safe 

and Eco-Effective - Cradle 

to Cradle Certif ed ProductTM 

(Silver Certif cate) 

Superior Products International II, Inc. spicoatings.com 

Exhibit D
-- •Win 

So. 

UA• 

o•a 

. 

--~...an Aoook - "'""' Hni:idutu N111ena 

r-\.Aolll.t South Afr 

...,aiwl'Joo 1'1110UDI

e 2:20-cv-02366 Document 1-5 Filed 07/28/20 

SUPERIOR PRODUCTS INTERNATIONAL PRESENCE 

Page 7 

Africa Australasia North 

America 

Angola Australia Canada 

Egypt New Zealand Mexico 

Nigeria U.S.A. 

South Africa 

Tanzania 

Asia 

China 

India 

Indonesia 

Japan 

Korea 

Malaysia 

Singapore 

Taiwan 

Thailand 

The 

Philippines 

Vietnam 

Europe 

Azerbaijan 

Belgium 

France 

Germany 

Greece 

Italy 

Netherlands 

Poland 

Russia 

Spain 

Turkey 

Ukraine 

Middle 

East 

Oman 

Saudi Arabia 

UAE 

South 

America 

Argentina 

Brazil 

Chile 

Colombia 

Trinidad & 

Tobago 

Venezuela 

Central 

America 

Dominican 

Republic 

Honduras 

Panama 

Puerto Rico 

PROTECTING INDUSTRIES WITH PREMIUM COATINGS 

Industries cannot rely on temporary efficiency when delivering peace of mind when it comes to combating high energy 

their products and systems. That’s why SPI Coatings work costs and corrosion. As operational problems become more 

for numerous corporations and individuals. Our coatings complex, SPI continues to push the boundaries of effectiveness 

were made to save you money because of their innovative and efficiency. SPI offers a system of products refi ned from 

performance and long-term durability. With an international remarkably conclusive data and forged under the most 

presence in a wide diversity of markets, SPI brings industries rigorous conditions. 

Superior Products International II, Inc. 

sales@spicoatings.com 

spicoatings.com 

Exhibit D