UNITED STATES OF AMERICA 

BEFORE THE FEDERAL TRADE COMMISSI 

In the Matter of 

ECM BioFilms, Inc., 

a corporation, also_ d/b/a 

Enviroplastics International 

) 

) 

) 

) 

) 

) _________________________) 

Docket No. 9358 

PUBLIC DOCUMENT 

COMPLAINT COUNSEL'S MOTION TO EXTEND THE WORD COUNT LIMIT 

Pursuant to Rule§ 3.22(f), Complaint Counsel asksAhe Court to extend the applicable 

word count limit by 2500 words with respect to the attached Motion To Certify Scheduling 

Issues to the Commission and Request for Interim Relief, and to afford Respondent the same 

extension with respect to its response. As long as the extension applies to both parties, 

Respondent does not object to the relief sought herein. 

This relief is appropriate for several reasons. First, the attached Motion reasonably could 

be divided into two separate motions (one addressing the certification, and another addressing 

interim scheduling relief). Under Rule§ 3.22(c), this alternative structure would entitle 

Complaint Counsel to submit two separate 2500-word filings. Second, because the Commission 

lacks the Court's experience with this litigation's procedural history, the filing requires 

additional detail. Third, the substantial importance of the issues raised waJ.Tants additional space. 

Finally, because the relief sought herein is reciprocal, there is no prejudice to Respondent. 

Accordingly, good cause exists to extend the word count limit. 

Dated: March 18, 2014 Respectfully submitted, 

Johnson (kjohnson3@ftc.gov) 

Jo an Cohen (jcohen2@ftc.gov) 

sa Jillson ( ejillson@ftc.gov) 

Federal Trade Commission 

600 Pennsylvania Ave., N.W. M-8102B 

Washington, DC 20580 

Phone: 202-326-2185; -2551; -3001 

Fax: 202-326-2551 
PUBLIC DOCU1\'IENT 

MEET AND CONFER CERTIFICATION 

The undersigned counsel certifies that Complaint Counsel conferred with Respondent's 

cotmsel in a good faith effort to resolve by agreement the issues raised by Complaint Counsel's 

Motion To Extend the Word Count Limit. Specifically, on March 18,2014, Complaint Counsel 

(Katherine Johnson, Jonathan Cohen, and Elisa Jillson) and Respondent's Counsel (Peter 

Arhangelsky and Lou Caputo) communicated by telephone regarding the issues this motion 

raises, and were able to reach an agreement. As long as the extension applies to both patties' 

filings, Respondent does not object to the relief sought herein. 

Dated: March 18,2014 

2 

Respectfully submitted, 

r Johnson (kjohnson3@ftc.gov) 

I an Cohen Gcohen2@ftc.gov) 

isa Jillson ( ejillson@ftc.gov) 

Federal Trade Commission 

600 Pennsylvania Ave., N.W. M-8102B 

Washington, DC 20580 

Phone: 202-326-2185; -2551; -3001 

Fax: 202-326-2551 
PUBLIC DOCUMENT 

UNITED STATES OF AMERICA 

BEFORE THE FEDERAL TRADE COMMISSION 

In the Matter of 

ECM BioFilms, Inc., 

a corporation, also d/b/a 

Enviroplastics International 

) 

) 

) 

) 

) 

) ___________________________ ) 

Docket No. 9358 

[PROPOSED] 

ORDER GRANTING COMPLAINT COUNSEL'S MOTION 

TO EXTEND THE WORD COUNT LIMIT 

This matter having come before the Chief Administrative Law Judge on March 18, 2014, 

upon a Motion by Complaint Counsel, and having considered all related submissions, and for 

good cause appearing, it is hereby ORDERED that Complaint Counsel's Motion Is GRANTED. 

The Court ORDERS that the word count applicable to Complaint Counsel's Motion To 

Certify Scheduling Issues to the Commission and Request for Interim Relief is extended by 2500 

words. 

It is FURTHER ORDERED that the word count applicable to ECM's response thereto is 

also extended by 2500 words. 

SO ORDERED: 

D. Michael Chappell 

Chief Administrative Law Judge 

Date: 

3 
PUBLIC DOCUMENT 

CERTIFICATE OF SERVICE 

I hereby certify that on March 18, 2014, I caused a true and correct copy of the foregoing 

to be served as follows: 

One electronic copy through the FTC's e-filing system, and one electronic courtesy copy to the 

Office of the Secretary: 

Donald S. Clark, Secretary 

Federal Trade Commission 

600 Pennsylvania Ave., NW, Room H-159 

Washington, DC 20580 

Email: secretary@ftc.gov 

One electronic courtesy copy and one paper courtesy copy to the Office of the Administrative Law 

Judge: 

The Honorable D. Michael Chappell 

Chief Administrative Law Judge 

600 Pennsylvania Ave., NW, Room H-110 

Washington, DC 20580 

One electronic copy to Counsel for the Respondent: 

Jonathan W. Emord 

Emord & Associates, P.C. 

11808 WolfRun Lane 

Clifton, VA 20124 

Email: jemord@emord.com 

Lou Caputo 

Emord & Associates, P .C. 

3210 S. Gilbert Road, Suite 4 

Chandler, AZ 85286 

Email: lcaputo@emord.com 

Peter Arhangelsky 

Emord & Associates, P.C. 

3210 S. Gilbert Road, Suite 4 

Chandler, AZ 85286 

Email: parhangelsky@emord.com 

I further certify that I possess a paper copy of the signed original of the foregoing 

document that is available for review by the parties and the adjuw·=a.c•U<. 

Date: March 18, 2014 

4 

ath · e Johnson (kjohnson3@ftc.gov) 

Jo an Cohen (jcohen2@ftc.gov) 

isa Jillson ( ejillson@ftc.gov) 

Federal Trade Commission 

600PennsylvaniaAve., N.W. M-8102B 

Washington, DC 20580 

Phone: 202-326-2185; -2551 ; -3001 

Fax: 202-326-2551