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UNITED STATES DISTRICT COURT 

FOR THE DISTRICT OF KANSAS 

Case No. 2:20-cv-02366-HLT-GEB 

FIRST AMENDED COMPLAINT FOR 

PERMANENT INJUNCTION AND OTHER 

EQUITABLE RELIEF

Plaintiff, the Federal Trade Commission (“FTC”), for its First Amended Complaint (the 

“Complaint”) alleges:

1. The FTC brings this action under Sections 13(b) and 19 of the Federal Trade 

Commission Act (“FTC Act”), 15 U.S.C. §§ 53(b), 57(b) and the 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), which authorize the FTC to 

seek, and the Court to order permanent injunctive relief, monetary relief, and other relief for 

Defendants’ acts or practices in violation of Section 5(a) of the FTC Act, 15 U.S.C. § 45(a) and 

in violation of the R-value Rule.

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. 

FEDERAL TRADE COMMISSION

Plaintiff,

v.

SUPERIOR PRODUCTS 

INTERNATIONAL II, INC., a corporation,

and

JOSEPH E. PRITCHETT, individually and 

as an officer of SUPERIOR PRODUCTS 

INTERNATIONAL II, INC.,

Defendants.

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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 

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. 

5. Defendants’ R-value claims since May 13, 2020, when amendments to the Rvalue Rule went into effect, violate the R-value Rule because they either are based on testing that 

does not comply with the Rule or do not fairly reflect the results of such testing. As stated 

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

directed, not the R-19 or RE-19 values that Defendants claim in their marketing materials. 

JURISDICTION AND VENUE

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

and 1345.

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

PLAINTIFF

8. 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.

9. 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 

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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

10. 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, 

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

coatings to consumers throughout the United States. 

11. 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

12. 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 

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

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

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14. 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.

15. 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,” 

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. 

16. 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. 

17. 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.

18. 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. 

19. R-value is a measurement of resistance to heat flow. See R-value Rule, 16 C.F.R. 

Part 460. 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).

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20. 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 

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

insulator. 

21. 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. 

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

23. 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

24. 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.

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

performance characteristics to Super Therm.” 

26. 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 

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. 

27. 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. 

28. 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. 

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

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

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

31. 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 

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

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

32. 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.” 

33. 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. 

34. 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.” 

35. 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. 

36. 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.” 

37. 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, 

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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:

Exhibit B at 6. 

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

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

39. 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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Exhibit B at 5. 

40. 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’ R-VALUE CLAIMS AFTER MAY 13, 2020

41. Since May 13, 2020, when the R-value Rule amendments took effect, Defendants 

continued making both express and implied R-value claims, including R-value equivalent claims, 

that exceeded the R-value of Super Therm as established by testing under the R-value Rule.

42. For example, from May 13, 2020 until at least August 14, 2020, Defendants 

claimed on their website that “testing demonstrated” as little as 10 mils of Super Therm, in their 

words, “credit card thickness,” had a lower k value (i.e., thermal conductivity) than three inches 

of traditional fiberglass batt insulation. They further explained, “[t]he lower the ‘k’ value, the 

better the R-value.” 

43. Defendants also continued circulating to their distributors claims that Super 

Therm has an R-19 equivalency when applied and dried to approximately 10 mils thickness. 

44. Defendants also made R-value claims directly to purchasers in response to 

inquiries regarding Super Therm’s performance characteristics. 

45. For example, on September 14, 2020, in response to a customer who inquired 

about “specification data” for Super Therm, Tim Cappel, Superior Products’ Vice President of 

Business Development, Technology, and Legal responded by “confirming that Super Therm can 

perform as an equivalent R 19.” 

46. On that same date, Cappel responded to another customer’s inquiry by providing 

a “Super Therm Equivalent Analysis” that stated that Super Therm has an “R-equivalent value” 

of 18.85. In that same document, Defendants concede that “because the thickness of Super 

Therm is only 254 microns it’s R-value is miniscule”.

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47. Defendants also made R-value claims to consumers after May 13, 2020 through 

their network of distributors. See Paragraphs 68-69, infra.

DEFENDANTS CLAIM THAT SUPER THERM AND SUNSHIELD 

SAVE CONSUMERS MONEY

48. 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.” 

49. 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. 

50. 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.” 

51. 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. 

52. After the FTC identified the claims in Paragraph 50, 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

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

54. 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. 

55. 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. 

56. 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. 

57. 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.

58. 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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59. 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. 

60. 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 ¶ 39) 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. 

61. 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. 

62. 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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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

63. 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. 

64. At all times relevant to this Complaint, these authorized distributors have acted as 

Superior Products’ agents with actual or apparent authority. 

65. 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. 

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

67. 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 

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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 

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 

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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 

“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 ¶ 37, 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, 

Case 2:20-cv-02366-HLT-GEB Document 90 Filed 08/30/21 Page 18 of 29
19

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.” 

68. R-value claims sourced from materials provided by Superior Products appeared 

ubiquitously on distributors’ websites after May 13, 2020, and many continue to be displayed. 

For example:

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

Environments of Canada (serving parts of the United States) includes a brochure 

prepared by Superior Products that claims Super Therm has an “RE 20” when two 

coats are applied at 10 mils each and “RE 19” when one coat is applied at 10 mils. 

b. Superior Products Coatings, Inc. of Georgia included a different brochure 

prepared by Superior Products that claims testing shows that Super Therm has 

“148% better performance than [three inches of] fiberglass” batt insulation by 

having a lower k value, and thus, a higher R-value than the fiberglass.

c. Coating Solutions of Texas claims on its website that Super Therm “can be used 

as replacement for traditional insulation on most substrates and in most 

conditions,” and includes a claim that testing establishes Super Therm has a much 

lower thermal conductance, and thus, higher R-value than fiberglass insulation. 

d. Real Invention Enterprises (USA) / Resonant Innovative Technologies LLP

(India) posted a video on YouTube.com on June 23, 2020 that is still displayed

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20

that states, “[TPRL] conducted a test that clearly and unequivocally proved that a 

coat of Super Therm with a thickness no bigger than a human hair produces an 

insulation rating that is equivalent to six to eight inches of comparable fiberglass 

insulation.” The video has extensive visuals of a residential home when 

discussing Super Therm. The distributor’s website contains another video about 

Super Therm (posted to YouTube February 26, 2020 and still present today) being 

applied to a residential container home with the statement, “With one coating [of 

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

equivalency.” Another video still on the distributor’s website today (posted to 

YouTube.com on February 26, 2020), states the ceramics in Super Therm “have 

allowed this coating to achieve an R-19 insulation value as tested by independent 

laboratories, or the equivalent of six to eight inches of fiberglass.”

e. NEOtech Coatings Australia Pty Ltd (“NEOtech”) posted a video to YouTube 

on April 22, 2020 that is still present today and claims that testing shows Super 

Therm is as effective “as fiberglass with an R 19 rating.” The distributor had a 

page on its website, as of May 20, 2021, titled “Super Therm insulation coatings 

for residential use,” describing Super Therm used on residential homes with the 

claim, “Super Therm Blocks 95% of Heat.” After the FTC showed that page to 

Defendants, it was removed, but the distributor continues to make other claims 

about Super Therm applied to residential homes in Florida and Nevada, and 

claims Super Therm “Insulates[;] 95% Heat Block.”

f. Power Correction Systems, Inc. includes on its website a “Certificate of 

Insulation” signed by JE Pritchett and stating: “Tested, analyzed, and measured 

Case 2:20-cv-02366-HLT-GEB Document 90 Filed 08/30/21 Page 20 of 29
21

for Thermal Insulation value of RE 19.” Its website further calls Super Therm 

“R19 Insulation.” 

g. South Point International Inc. claims on its website that “Super Therm has been 

tested to have an RE-19 value compared to traditional insulation.” It further 

claims that the basis for Super Therm’s “RE-19 value” is “the ASTM C-236 

hotbox, BTU conduction test, Merrimac testing performed on shipping containers, 

and tests by VTEC laboratories.” South Point also claims that “Super Therm can 

be used as a replacement for traditional insulation on most substrates and in most 

conditions.” Its website also contains brochures and technical data sheets created 

by Superior Products that claim variously that Super Therm has an “RE 19” and 

“RE 20” depending on the number of coats applied. Those marketing materials 

also claim that users can “apply a R-19 equivalent rating to your facility with a 

single coat’ and that “a layer of Super Therm no thicker than a single business 

card provides the same protection as 6 inches of fiberglass” insulation and that 

Super Therm provides a “benefit comparable to R 19.” 

69. Beginning in early 2020, NEOtech sent marketing videos about Super Therm to 

Pritchett for review and approval that were based on claims from Superior Products. Pritchett 

reviewed and provided editorial comments. When a question was raised about Defendants’ 

dealings with the FTC and NEOtech’s claims, for example, that “Super Therm® Insulation 

Coating blocks 95% of heat - 99% BTU Rating Tested,” Pritchett responded on April 1, 2020, 

“you are not in the US and can do this,” and then, “No restriction. Use them.” On April 8, 2020, 

Pritchett sent links to NEOtech’s Super Therm YouTube videos to Superior Products’

distributors in the United States and elsewhere, stating, “Shane in Australia put these videos 

Case 2:20-cv-02366-HLT-GEB Document 90 Filed 08/30/21 Page 21 of 29
22

together to help everyone out with marketing.” On May 1, 2020, Pritchett told NEOtech and 

Superior Products’ U.S. employees, “The video collection is perfect for everyone to use,” and 

offered Superior Products’ “help . . . to get them on line or into YouTube for public view.” On 

May 13, 2020, Pritchett informed U.S. distributors about the videos “that you can download and 

use” and added, “I encourage you to make contact with Shane and discuss how best to set this up 

for your own ... use.” On December 16, 2020, Pritchett again promoted a Super Therm 

marketing video by NEOtech to distributors in the United States, telling them, “it is fantastic”

and describing NEOtech’s website as “very good.” 

70. Consumers in the United States, including residential homeowners, see the claims 

made by Superior Products’ foreign distributors and contact them for information. Those U.S. 

consumers are then referred to Superior Products or its U.S. distributors for sales. Based on 

Defendants’ emails and sworn testimony, this practice occurred prior to May 13, 2020 and 

continues today.

71. 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 AND ENERGY SAVINGS

CLAIMS ARE FALSE OR UNSUBSTANTIATED

72. 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. 

73. 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 

Case 2:20-cv-02366-HLT-GEB Document 90 Filed 08/30/21 Page 22 of 29
23

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.” 

74. 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:

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.

75. 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. 

76. 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. 

77. 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.”

Case 2:20-cv-02366-HLT-GEB Document 90 Filed 08/30/21 Page 23 of 29
24

78. 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 ¶ 73, 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.” 

79. 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 

80. 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.

81. 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

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

documents containing false and deceptive claims to their distributors. 

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VIOLATIONS OF THE FTC ACT

83. 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.

COUNT I

False or Unsubstantiated Performance Claims 

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

sale, or sale of Super Therm and Sunshield, as described in Paragraphs 24-52, 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. 

85. The representations set forth in Paragraph 84 are false and misleading and were 

not substantiated at the time the representations were made.

86. Therefore, the making of the representations as set forth in Paragraph 84

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

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

sale, or sale of Super Therm and Sunshield, as described in Paragraphs 53-6261, Defendants 

have represented, directly or indirectly, expressly, or by implication, that testing establishes an 

R-value or R-value equivalent of R-19 for Super Therm. 

Case 2:20-cv-02366-HLT-GEB Document 90 Filed 08/30/21 Page 25 of 29
26

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

89. Therefore, the representations in Paragraph 87 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). 

COUNT III

Means and Instrumentalities

90. 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).

VIOLATIONS OF THE R-VALUE RULE

91. The R-value Rule was issued by the Commission under Section 18 of the FTC 

Act, 15 U.S.C. § 57a. The Rule became effective on September 29, 1980. The Commission 

amended the Rule on March 28, 1996, May 31, 2005, and May 13, 2019, under Section 18 of the 

FTC Act, 15 U.S.C. §57a, and these amendments became effective on April 29, 1996, November 

28, 2005, and May 13, 2020, respectively. The Rule specifies substantiation and disclosure 

requirements for insulation products used in the residential market, for non-insulation products 

marketed with R-value claims, and prohibits certain claims unless they are true.

92. Section 460.5 of the Rule requires that R-values given in labels, fact sheets, 

advertisements, and other promotional materials must be based on tests conducted under the 

methods listed in the Rule.

93. Section 460.22 of the Rule requires that where an advertiser makes an R-value 

claim for an product, other than a fenestration-related product, that is not home insulation and is 

Case 2:20-cv-02366-HLT-GEB Document 90 Filed 08/30/21 Page 26 of 29
27

marketed in whole or in part to reduce residential energy use by slowing heat flow, the advertiser 

must test the product pursuant to Section 460.5 using a test or tests in that section appropriate to 

the product. Section 460.22 of the Rule also requires that “[a]ny advertised R-value claims must 

fairly reflect the results of those tests.”

94. Pursuant to Section 460.1 of the Rule, 16 C.F.R. § 460.1, and Section 18(d)(3) of 

the FTC Act, 15 U.S.C. §57a(d)(3), a violation of the R-value Rule constitutes an unfair or 

deceptive trade practice in or affecting commerce, in violation of Section 5(a) of the FTC Act, 15 

U.S.C. §45(a). 

Count IV 

Violations of the R-Value Rule

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

sale, or sale of Super Therm and Sunshield, as described in paragraphs 13-18, 41-52 and 68-70, 

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

A. Super Therm has an R-value of R-20, R-19, or provides a benefit equivalent to 

R-20 or R-19.

B. Super Therm has an R-value that is higher than 3-inches of fiberglass batt 

insulation or that is the same as 6-inches of fiberglass batt insulation.

C. Sunshield has similar performance characteristics as Super Therm.

D. Super Therm and Sunshield reduce residential energy use by slowing heat 

flow.

96. The R-value claims set forth in Paragraph 95 were based on testing that did not 

comport with the testing described in Section 460.5 of the Rule or did not fairly reflect the results 

of such testing, as set forth in Paragraphs 72-79.

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28

97. Therefore, the acts or practices as set forth in Paragraphs 95-96 violate the Rvalue Rule, 16 C.F.R. §460.22. 

CONSUMER INJURY

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

injury because of Defendants’ violations of the FTC Act and the R-value Rule. 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.

PRAYER FOR RELIEF

99. Wherefore, Plaintiff FTC, requests that the Court:

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

Defendants;

B. Award monetary and other relief within the Court’s power to grant; and

C. 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

* * *

Case 2:20-cv-02366-HLT-GEB Document 90 Filed 08/30/21 Page 28 of 29
29

Respectfully submitted,

DUSTON J. SLINKARD

Acting 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: August 30, 2021

REILLY DOLAN

General Counsel (Acting)

s/ Jonathan W. Ware________________

JONATHAN W. WARE (DC SBN 989414)

Pro hac vice

ADRIENNE LIGHTEN (DC SBN 1045911)

Pro hac vice

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

Case 2:20-cv-02366-HLT-GEB Document 90 Filed 08/30/21 Page 29 of 29
INDEX OF EXHIBITS TO

PLAINTIFF FEDERAL TRADE COMMISSION’S

FIRST AMENDED 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 (2015-2021)

Case 2:20-cv-02366-HLT-GEB Document 90-1 Filed 08/30/21 Page 1 of 1
Exhibit A

Case 2:20-cv-02366-HLT-GEB Document 90-2 Filed 08/30/21 Page 1 of 4
Exhibit A

Case 2:20-cv-02366-HLT-GEB Document 90-2 Filed 08/30/21 Page 2 of 4
Exhibit A

Case 2:20-cv-02366-HLT-GEB Document 90-2 Filed 08/30/21 Page 3 of 4
Exhibit A

Case 2:20-cv-02366-HLT-GEB Document 90-2 Filed 08/30/21 Page 4 of 4
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.
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. U V re p res en t s 3 % o f h e at l o a d

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 mal E m m 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 i o 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 g h 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. National Me a s u rement 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.

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. U V re p res en t s 3 % o f h e at l o a d

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 mal E m m 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 i o 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 g h 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. National Me a s u rement 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. U V re p res en t s 3 % o f h e at l o a d

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 mal E m m 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 i o 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 g h 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. National Me a s u rement 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.
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.

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.
 	


	
	




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Exhibit C

Case 2:20-cv-02366-HLT-GEB Document 90-4 Filed 08/30/21 Page 4 of 4
Achieve optimum cooling with a coating that blocks and repels radiational heat.

SUPER THERM®

Protecting industries with premium coatings

Exhibit D

0-cv-02366-HLT-GEB Document 90-5 Filed 08/30/21 P
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.

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 benefi t.

Super Therm®

Experience Innovative Insulation

Superior Products International II, Inc. spicoatings.com

■ 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.

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 refl ect radiational heat 

away from protected areas 

when applied to a surface. 

By allowing only 5% heat 

Exhibit D

0-cv-02366-HLT-GEB Document 90-5 Filed 08/30/21 P
Super Therm® passed 

NASA testing with 

Best Test Result. 

Superior Products International II, Inc. spicoatings.com

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)

• 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 

ineffi ciencies 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

SUPER THERM® VS. TRADITIONAL INSULATION

A Comparison of Popular 

Insulation Options

Exhibit D

0-cv-02366-HLT-GEB Document 90-5 Filed 08/30/21 P
THERMAL STUDY

JUAYMAH NGL SPHEROID TANKS

Super Therm®

NG Tank Spheroid 203A

Saudi Aramco – November 2013

Existing Tank

NG Tank Spheroid 203B

SUPER THERM® IN USE TODAY

Aviation

Tucson International Airport

Arizona, U.S.

Oil and Gas

Mitsubishi Oil Terminal

Osaka, Japan

Marine

Blue Chip Casino Ship

Indiana, U.S.

Offshore

GDF Suez

North Sea, U.K.

Residential

Residential Neighborhood

Arizona, U.S.

Transportation

Pacifi c Shipping 

and Trucking

Telecommunications

Vodaphone Group PLC

Tourism

Address Hotel 

Dubai, U.A.E.

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

22% overall energy reduction 

with 40% HVAC savings

52 ̊C roof temperature before 

application, 42 ̊C after completion

Reduced evaporation of fi nished 

petrochemicals

Super Therm® provides sound 

dampening and color options

Temperature of coatings and 

other materials in sunlight

Exhibit D

0-cv-02366-HLT-GEB Document 90-5 Filed 08/30/21 P
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 

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. 

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

40 to 60% of total 

building energy costs 

directly relate to air 

conditioning expense. 

Beat the heat build-up 

with Super Therm®. 

PROTECTING INDUSTRIES WITH PREMIUM COATINGS

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. 

In this study, the solar refl ectance 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 refl ectivity was 80% and 

after 1.5 years their refl ectivity 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. 

Superior Products International II, Inc. spicoatings.com

Certifi ed Environmentally Safe 

and Eco-Effective - Cradle 

to Cradle Certifi ed ProductTM 

(Silver Certifi cate)

100%

0

250 750 1250 1750 2250

10

20

30

40

50

60

70

80

90

Wavelength (nm)

Total Solar Reflectance = 96.01%

PCT Reflectance

Super Therm® Solar Energy Refl ectance Chart

Exhibit D

0-cv-02366-HLT-GEB Document 90-5 Filed 08/30/21 P
SUPERIOR PRODUCTS INTERNATIONAL PRESENCE

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

Africa

Angola 

Egypt 

Nigeria 

South Africa

Tanzania

Australasia

Australia 

New Zealand

North 

America 

Canada 

Mexico 

U.S.A.

Superior Products International II, Inc.

sales@spicoatings.com

spicoatings.com

PROTECTING INDUSTRIES WITH PREMIUM COATINGS

Industries cannot rely on temporary effi ciency when delivering 

their products and systems. That’s why SPI Coatings work 

for numerous corporations and individuals. Our coatings 

were made to save you money because of their innovative 

performance and long-term durability. With an international 

presence in a wide diversity of markets, SPI brings industries 

peace of mind when it comes to combating high energy 

costs and corrosion. As operational problems become more 

complex, SPI continues to push the boundaries of effectiveness

and effi ciency. SPI offers a system of products refi ned from 

remarkably conclusive data and forged under the most 

rigorous conditions. 

Exhibit D

0-cv-02366-HLT-GEB Document 90-5 Filed 08/30/21 P