UNITED STATES OF AMERICA 

BEFORE THE FEDERAL TRADE COMMISSI 

OFFICE OF THE ADMINISTRATIVE LAW JUD 

Washington, D.C. 

In the Matter of 

ECM BioFilms, Inc., 

a corporation, also d/b/a 

Enviroplastics International, 

Respondent. 

Docket No. 9358 

PUBLIC 

569290 

RESPONDENT'S (SECOND) SUPPLEMENT TO MOTION TO SANCTION 

COMPLAINT COUNSEL FOR UNAUTHORIZED DISSUASION OF RESPONSE TO 

SUBPOENA DUCES TECUM 

ECM BioFilms, Inc. (ECM), by counsel, hereby supplements its pending Motion to 

Sanction Complaint Cmmsel for Unauthorized Dissuasion of Response to Subpoena Duces 

Tecum ("Motion") with the attached new inf01mation. Yesterday, March 27, 2014, Complaint 

Counsel filed its combined Opposition to Respondent's Motion to Sanction Complaint Counsel 

for Unauthorized Interference with a Third Party Subpoena (filed Mar. 19, 2014). To assme a 

complete record before this Comt, ECM hereby submits a third contact between Matthew J. 

Wilshire, an attomey working for the FTC's Bmeau of Consumer Protection, and Dr. Frederick 

Michel. Mr. Wilshire, on behalf of the bmeau and acting without leave of comt, again directs 

Dr. Michel in the manner, content, and timing of his subpoena response to ECM. The email is 

dated March 28, 2014 and, so, it was lmavailable to ECM cmmsel before the date of this 

Supplement. 

Respectfully submitted, 

Is/ Jonathan W Emord 

Jonathan W. Emord (jemord@emord.com) 

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PUBLIC DOCUMENT

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 EMORD & ASSOCIATES, P.C. 

 11808 Wolf Run Lane 

 Clifton, VA 20124 

 Telephone: 202-466-6937 

 Facsimile: 202-466-6938 

DATED this 28th day of March 2014. 
PUBLIC DOCUMENT

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CERTIFICATE OF SERVICE 

I hereby certify that on April 2, 2014, I caused a true and correct copy of the foregoing 

{PUBLIC} filing to be served as follows: 

One copy to the Office of the Secretary through the e-filing system: 

Donald S. Clark, Secretary 

Federal Trade Commission 

600 Pennsylvania Ave., NW, Room H-113 

Washington, DC 20580 

Email: secretary@ftc.gov 

One electronic courtesy copy to the Office of the Administrative Law Judge:

The Honorable D. Michael Chappell 

Administrative Law Judge 

600 Pennsylvania Ave., NW, Room H-110 

Washington, DC 20580 

One electronic copy to Counsel for Complainant:

Katherine Johnson (kjohnson3@ftc.gov) 

Federal Trade Commission 

600 Pennsylvania Avenue, NW 

Mail stop M-8102B 

Washington, D.C. 20580 

Elisa Jillson (ejillson@ftc.gov) 

Federal Trade Commission 

600 Pennsylvania Avenue, NW 

Mail stop M-8102B 

Washington, D.C. 20580 

 Jonathan Cohen (jcohen2@ftc.gov) 

Federal Trade Commission 

600 Pennsylvania Avenue, NW 

Mail stop M-8102B 

Washington, D.C. 20580 

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

document that is available for review by the parties and adjudicator consistent with the 

Commission’s Rules. 

DATED: April 2, 2014 

 /s/ Jonathan W. Emord 

 Jonathan W. Emord 

 EMORD & ASSOCIATES, P.C. 

 11808 Wolf Run Lane 

 Clifton, VA 20124 

 Telephone: 202-466-6937
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