CASE NO. _______________ 

COMPLAINT FOR PERMANENT 

INJUNCTION AND OTHER 

EQUITABLE RELIEF 

Case 3:20-cv-08190-DWL Document 1 Filed 07/28/20 Page 1 of 10 

ALDEN F. ABBOTT 

General Counsel 

MICHELLE L. SCHAEFER, DC Bar No. 478773 

JONATHAN W. WARE, DC Bar No. 989414 

Federal Trade Commission 

600 Pennsylvania Ave., NW 

Maildrop CC-9528 

Washington, DC 20580 

202-326-3515, mschaefer@ftc.gov (Schaefer) 

202-326-2726, jware1@ftc.gov (Ware) 

Attorneys for Plaintiff Federal Trade Commission 

UNITED STATES DISTRICT COURT 

FOR THE DISTRICT OF ARIZONA 

FEDERAL TRADE COMMISSION 

Plaintiff, 

v. 

SUPERTHERM, Inc., a corporation, 

ROBERTO GUERRA, individually and as 

an officer of SUPERTHERM, Inc., and 

SUSANA GUERRA, individually and as an 

officer of SUPERTHERM, Inc. 

Defendants. 

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

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

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

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

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Case 3:20-cv-08190-DWL Document 1 Filed 07/28/20 Page 2 of 10 

disgorgement of ill-gotten monies, and other equitable relief for Defendants’ acts or 

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

2. Defendants market their MultiCeramics Insulation coating using deceptive 

claims related to R-values, which measure the insulating ability of materials, including 

home insulation. 

3. Defendants claim that their MultiCeramics Insulation coating provides the 

equivalent of R-19. 

4. However, this claim is false. Therefore, Defendants cannot substantiate it. 

In fact, Defendants’ MultiCeramics Insulation coating has an R-value that is substantially 

less than one when applied as Defendants instruct. 

JURISDICTION AND VENUE 

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

1337(a), and 1345. 

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

PLAINTIFF 

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

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

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

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

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

may be appropriate in each case, including rescission or reformation of contracts, 

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Case 3:20-cv-08190-DWL Document 1 Filed 07/28/20 Page 3 of 10 

restitution, the refund of monies paid, and the disgorgement of ill-gotten monies. 15 

U.S.C. § 53(b). 

DEFENDANTS 

9. Defendant SUPERTHERM, Inc. (“SuperTherm”) is an Arizona corporation 

with its principal place of business at 4305 W. Sarah Rd., Prescott, AZ 86305. 

SuperTherm 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, SuperTherm has advertised, marketed, distributed, or sold MultiCeramics 

Insulation to consumers throughout the United States. 

10. Defendant Roberto Guerra is the founder and a principal of SuperTherm. 

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 

and practices of SuperTherm, including the acts and practices set forth in the Complaint. 

Defendant Roberto Guerra resides in this District and, in connection with the matters 

alleged herein, transacts or has transacted business in this District. 

11. Defendant Susana Guerra is SuperTherm’s President and Director. At all 

times material to this Complaint, acting alone or in concert with others, she has 

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

and practices set forth in the Complaint. Defendant Susana Guerra resides in this District 

and, in connection with the matters alleged herein, transacts or has transacted business in 

this District. 

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Case 3:20-cv-08190-DWL Document 1 Filed 07/28/20 Page 4 of 10 

COMMERCE 

12. At all times material to this Complaint, Defendants have 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 and 

commercial applications, including “MultiCeramics Insulation.” 

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 MultiCeramics Insulation is an “Insulation Coating 

RE19” and that it is an “R Equivalent INSULATION COATING THAT REALLY 

WORKS!” See Exhibit A at 1. 

16. Since at least 2014, Defendants have disseminated or caused the 

dissemination of advertising, packaging, and promotional materials for their 

MultiCeramics Insulation coating, including through advertisements on their website. 

17. In these promotional materials, Defendants describe their product in terms 

of R-values and R-value equivalents. For example, they claim that 

“MULTICERAMICSTM provides R equivalent ‘RE’ insulation.” See Exhibit B at 1. 

They also advertise their product as “Multi-Ceramics Insulation Coating RE19.” See 

Exhibit A at 1. Defendants market their product for “residential and commercial 

buildings.” See Exhibit D at 1. 

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Case 3:20-cv-08190-DWL Document 1 Filed 07/28/20 Page 5 of 10 

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

Regulation Rule Concerning the Labeling and Advertising of Home Insulation (“R-value 

Rule” or “Rule”), 16 C.F.R. Part 460 (initially issued in 1980 and last amended in 2019). 

The greater the R-value, the greater the reduction in heat flow, and the more energy may 

be saved to heat or cool a building. 70 Fed. Reg. 31,258 (2005). 

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

among the most common insulating materials in the United States. It generally has an Rvalue 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. 

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

homes. It divides the country into eight climate zones and lists R-values for each zone. 

The District of Arizona is in Zones 2-5. The Department recommends homes in Zone 2 

should have R-30 to R-60 insulation in the attic, and that homes in Zone 5 should have R49 to R-60 insulation in the attic. Thus, if a home in this District is using fiberglass batt 

(at R-3.8 per inch), then it should have at least 7-8 inches of the batt in its attic to obtain 

the R-30 level. 

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

5 
 

 

Case 3:20-cv-08190-DWL Document 1 Filed 07/28/20 Page 6 of 10 

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

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

by the Commission. 

DEFENDANTS CLAIM MULTICERAMICS INSULATION COATINGS 

PROVIDE R EQUIVALENT INSULATION WITH AN R-VALUE EQUIVALENT 

OF “RE19” 

23. Defendants market their product as “Multi-Ceramics Insulation Coating 

RE19.” See Exhibit A at 1. They claim MultiCeramics Insulation is an “R Equivalent 

INSULATION COATING THAT REALLY WORKS!” Id. They say their product 

“[p]rovides insulation, thus avoiding the heat from entering the building.” See Exhibit E 

at 1. 

24. Defendants also claim that consumers will reap the benefits of this 

purported insulation value from even a thin coat of MultiCeramics Insulation. They 

claim that their product “INSULAT[ES] WITH A SINGLE COAT NO THICKER 

THAN A BUSINESS CARD.” See Exhibit C at 3. They go on to say that 

MultiCeramics provides “R Equivalence with a 0.007 coat (Interior App.)” See Exhibit 

A at 1. According to Defendants, “MultiCeramicsTM Superior Roofing System features 

an insulating factor only slightly less than products up to 20 times its thickness.” See id. 

at 2. 

25. As a two-person company, Defendants Roberto and Susana Guerra control 

and manage their business’s day-to-day operations, including their website and marketing 

materials. Additionally, Defendant Roberto Guerra is responsible for the company’s 

6 
 

Case 3:20-cv-08190-DWL Document 1 Filed 07/28/20 Page 7 of 10 

product development and prepares the advertisements for the MultiCeramics Insulation 

coatings. 

DEFENDANTS’ R-VALUE AND R-VALUE EQUIVALENT 

CLAIMS ARE FALSE OR UNSUBSTANTIATED 

26. MultiCeramics Insulation coatings do not significantly restrict heat flow, 

much less to the extent claimed by Defendants. Indeed, the R-value of MultiCeramics 

Insulation coatings applied at the recommended thickness is considerably less than one. 

DEFENDANTS’ CLAIMS ARE MATERIAL 

27. Defendants specifically identify “Insulation” as the “PRODUCT USE” for 

MultiCeramics Insulation. See Exhibit F at 1. 

28. Defendants claim that MultiCeramics Insulation “outperform[s] other 

insulation coatings,” and tout the product’s “PAY BACK RATIO TO INVESTMENT.” 

VIOLATIONS OF THE FTC ACT 

29. 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 

30. In numerous instances in connection with the advertising, promotion, 

offering for sale, or sale of MultiCeramics Insulation, as described in Paragraphs 13-28, 

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

7 
 

Case 3:20-cv-08190-DWL Document 1 Filed 07/28/20 Page 8 of 10 

MultiCeramics Insulation Coatings have insulation values or insulation equivalent values 

of R-19 when used at normal levels. 

31. The representation set forth in Paragraph 30 is false or misleading, or was 

not substantiated at the time the representations were made. 

32. Therefore, the making of the representation set forth in Paragraph 30 

constitutes a deceptive act or practice in violation of Section 5(a) of the FTC Act, 15 

U.S.C. § 45(a). 

CONSUMER INJURY 

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

substantial injury as a result of Defendants’ violations of the FTC Act. In addition, 

Defendants have been unjustly enriched as a result of their unlawful acts or practices. 

Absent injunctive relief by this Court, Defendants are likely to continue to injure 

consumers, reap unjust enrichment, and harm the public interest. 

THIS COURT’S POWER TO GRANT RELIEF 

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

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

redress violations of any provision of law enforced by the FTC. The Court, in the 

exercise of its equitable jurisdiction, may award ancillary relief, including rescission or 

reformation of contracts, restitution, the refund of monies paid, and the disgorgement of 

ill-gotten monies, to prevent and remedy any violation of any provision of law enforced 

by the FTC. 

8 
Case 3:20-cv-08190-DWL Document 1 Filed 07/28/20 Page 9 of 10 

PRAYER FOR RELIEF 

35. Wherefore, Plaintiff FTC, pursuant to Section 13(b) of the FTC Act, 15 

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

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

likelihood of consumer injury during the pendency of this action and to 

preserve the possibility of effective final relief, including a preliminary 

injunction; 

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

Defendants; 

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

consumers resulting from Defendants’ violations of the FTC Act, including 

but not limited to, rescission or reformation of contracts, restitution, the 

refund of monies paid, and the disgorgement of ill-gotten monies; and 

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

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

* * * 

9 
Case 3:20-cv-08190-DWL Document 1 Filed 07/28/20 Page 10 of 10 

Dated: July 28, 2020 

Respectfully Submitted, 

ALDEN F. ABBOTT 

General Counsel 

s/ Jonathan W. Ware_____________________ 

MICHELLE L. SCHAEFER, DC Bar No. 478773 

JONATHAN W. WARE, DC Bar No. 989414 

Federal Trade Commission 

600 Pennsylvania Ave., NW 

Maildrop CC-9528 

Washington, DC 20580 

202-326-2726, jware1@ftc.gov 

202-326-3515, mschaefer@ftc.gov 

202-326-3197 (fax) 

Counsel for Plaintiff Federal Trade Commission 

10 
   

Case 3:20-cv-08190-DWL Document 1-2 Filed 07/28/20 Page 1 of 3 

Exhibit A 
 

 

ulti-Ceramics Insulation Coating RE 19 

Criteria for solar reflectance: 

Flat and Low Slope Initial solar After 3rd Year 

Roof pitch reflectance solar reflectance 

Energy star: =or< 2:12 65% 50% 

EZ Cool Roof: = or < 2:12 82.2% 78.2% 

era 

After 10 

years 

Not rated 

' 74% 

ui_ 

. '~ 

- No FadeAcryiic"Stuccc,, 

No Fade TM Color Retention 

CI ear Coatings 

High Temperature Coatings 

Ct1uosion En,apsulalion 

Marb e Emutabon Coat 

Email Support 

2/21/2019 Case 3:20-cv-08190-DWL Document 1-2 Filed 07/28/20 Page 2 of 3 Multi-Ceramics Insulation

R Equivalent INSULATION COATING THAT REALLY WORKS!

Technology for Energy Conservation 

MULTICERAMICS outperform other insulation Now you have the information! Stopping climate

coatings: change starts with you today, because it takes less

R Equivalence with a 0.007 coat (Interior App.) With NO FADE resources to conserve 40% of the energy production,

and Cool Touch Technology than to build the infrastructure to produce 40% more

R Equivalence with just 0.007 coat energy.

Sound Blockage 

MultiCeramicsTM Technology line

Outperforms Energy Star Best 

Surpases California Cool Roof Program 

Tested better overall than the most expensive options

Works on Interior/Exterior

Class "A" Rated "0" Flame Spread

Passed 5000 hours Salt spray tests

USDA Approved

Water Proof (Not just water resistant)

Blocks 99.5% of Infrared

Resists Mold & Mildew

25 Years residential life expectancy

K value (0.07) ASTM Testing 

PAY BACK RATIO TO INVESTMENT:

Solar photovoltaic systems : 5 to 20 years

Appliances: 10 + years

Weatherization: 20 years

MULTICERAMICS: 1 1/2 year

Do The Math!

MULTICERAMICSTM Really works!

MicroPacking Vs. Plating

MultiCeramicsTM technology provides corrosion protection and "MicroPacking" that reduces surfaces maintenance many times the normal life span of any application, it saves energy,

provides longer life to properties and surfaces. Unlike the alternative fiberglass or foams, it poses no health hazards and offers greater comfort by outperforming all others under most

conditions. MultiCeramicsTM is the ultimate insulation material.

Chemically Different

MultiCeramicsTM EZ Cool Roof System unique performance characteristics are based on a polymer chemistry that is amorphous, rather than

crystalline, in nature. Crystalline liquids dry to a bed of thousands of tiny individual crystals, which can separate under maintenance traffic,

temperature variations, or normal building flexion. Amorphous chemistries process a random molecular structure, drying to a fibrous, continuous

film, with 25 times the elasticity of fiberglass felt.

High Strength to Weight

The MultiCeramicsTM Superior Roofing System was developed with space age characteristics-unusual strength combined with weight that is up to 90%

less than competing products. Combining a penetrating base coat with the spun-bond, continuous-filament polyester backbone fabric POLYFAB

MultiCeramicsTM Is a TECHNOLOGY!

Built with a blend of nano acrylics and

polymers, which makes it flexible, yet

tough It has Multi- ceramics technology

to give not only reflective abilities but

also non-conductive ability for heat and

cold. Other electrometric reflective

coatings as well as the many "ADD ON

CERAMICS to cheap paint" type, have

only one acrylic and a single reflective

ceramic. MultiCeramicsTM ceramics are

not the rough multifaceted type as the

one found in other coatings,

MultiCeramicsTM ceramics are specially

manufactured. The unique size, types

and shapes permits the ceramics to

settle very tight together and not

allowing air to interact between the

ceramics producing the "Micro Packing"

effect, this far surpasses older

technology.

Proving-Ground Tough

While MultiCeramicsTM is a space age

chemical formulation, it is a fully tested

product. It was derived after carefully

documenting the performance

http://www.supertherm.net/multicera.htm 1/2
REFLECTIVITY 

 No Fade coaung 

 Conventional Paint 

Multi-Ceramics - True Space Age Insulation Coating 

2/21/2019 Case 3:20-cv-08190-DWL Document 1-2 Filed 07/28/20 Page 3 of 3 Multi-Ceramics Insulation

weighing but 2.2 oz/sq. yd. (75 gr/m)- the complete system including reflective topcoat is no thicker than a dime, yet is strong enough to support a

footprint-sized weight in excess of 3500 pounds (1589 kg) before bursting.

Dimensional Stability

MultiCeramicsTMEZ Cool Roof System when bent, returns to its precise linear dimensions within a ± tolerance. It remains 99% dimensionally stable

throughout its useful life. This linear flexing without cracking or dimensional changes facilitates MultiCeramicsTM installation around cooler bases,

exhaust chimneys and up parapets, and assures a continuous self-flashing, weather resistant seal over the entire roof's surface.

Fire Resistant

The MultiCeramicsTM Superior Roofing System offers an additional benefit to commercial and residential users in dry or fire-prone areas. While no

lightweight roofing material is fireproof, MultiCeramicsTM has no flash point. Should an outside flame be applied directly to the roof's surface, the

material itself will deteriorate, but will not ignite.

Embrittling-Resistant

After years in the sun, or of enduring climatic extremes, petroleum-based roofing matter can become brittle, and crack. MultiCeramicsTM has been

formulated specifically to withstand the searing heat of the Arizona deserts while retaining inherent structural flexibility. To date, industrial and

residential applications have undergone in excess to 105,120 hours of continuous exposure to the desert climate, including day/night temperature

variations of 60 degrees (16o C) without failure and without embrittling.

Water Proof NOT "Moisture Proof"

The MultiCeramicsTM EZ Cool Roof System continuous-filament, single-ply, fluid applied superior roofing system provides one of the most efficient

long-life moisture barriers available in the industry today, with a moisture-vapor transmission rate of just 0.94 perms per mil.

No Added Plasticizers or Flame Retardants

The flexible, non-combustive qualities of the MultiCeramicsTM, Superior Roofing System are inherent in the product's chemical formulation, and remain

properties of the cured film throughout its life. Some competitive coatings contain plasticizers and flame retardant additives, which leach out over

time, causing the coating to become brittle and crack, permitting moisture to penetrate substrate materials.

Long Life, Little Labor

Direct roofing costs can be divided into two categories, materials and labor. Labor traditionally Constitutes the greater percentage of such costs.

MultiCeramicsTM EZ Cool Roof System was designed to reduce labor costs by:

1) Permitting application by unskilled labor, with hand tools only.

2) Lasting longer than ordinary roofs.

3) Its ability to be applied over virtually any sound old-roof surface, without expensive tear-off procedures.

4) Its inherent ease of maintenance. Should wear of surface fissures occur for any reason, they are readily repaired by one individual with a container of MultiCeramicsTM, a paint

brush and POLYFAB fabric. 

Energy Savings

Traditional roofs do more than divert the elements. In the past, they have also served as heat sinks, absorbing the sun's heat and redistributing it throughout building interiors-to the

distress of occupants and the delight of utility companies. MultiCeramicsTM was formulated as both insulator and reflector designed to maintain comfortable interior temperatures at

reduced utility cost. Formal testing indicates a solar reflectance for the product of 82.2%, more than three times greater than gravel-coat asphalt. As a result interior temperatures are

reduced by up to 30oF (17o C) and roof expansion and contraction are held to minimum. In addition to this uniquely high reflectance capability, the MultiCeramicsTM Superior Roofing

System features an insulating factor only slightly less than products up to 20 times its thickness. MultiCeramicsTM roofs have reduced interior temperatures by as much as 30 degrees in

retrofit applications. Should design requirements dictate, the product is available in the full spectrum of colors. Reflective characteristics will vary with the color density selected. Check

with your MultiCeramicsTM representative for specific information.

characteristics of countless individual

compounds. It has been "torture-tested"

by such unusual applications as water

pool walls and hot muffler patches. It

has been proven in actual use

throughout the United States and

abroad under the most rigorous climatic

conditions, and tested effective from

subfreezing to searing desert

temperatures. When used according to

factory recommendations, it simply do

not fail.

©Copyright TDE Group

SUPERTHERM Inc.

1999,2008

Phones : 

888-887-0144 - 928-443-0685

http://www.supertherm.net/multicera.htm 2/2
   

Case 3:20-cv-08190-DWL Document 1-3 Filed 07/28/20 Page 1 of 3 

Exhibit B 
 

2/21/2019 Case 3:20-cv-08190-DWL Document 1-3 Filed 07/28/20 Page 2 of 3 WALLPANEL Corporate Home Page

SUPERTHERM Inc. 

Green Efficiency and Beauty

Are some of the added benefits Architects,

Builders and contractors enjoy when

designing and building with the

WALLPANELTM wall panel System. 

Any project that includes Energy

Conservation, Green Points, Speed or

Budgetary constrains, can be accomplished

exceeding the highest expectation. 

WALLPANELTM System does not requires

structural engineering stamps for every

modification to the wall panels. 

Simplicity and Strength

It takes cutting 60 or more trees to build a house with wood, that is not

"Green" WALLPANEL system does not use or need wood.

The HIGHTHERM R24 - SUPERTHERMTM R30 - or SUPERTHERMAL

R60 true insulation wall panels designed for commercial and residential

applications, when conservation is a must this system is designed to

achieve a super insulated stable structure that makes erecting

residential building a simple task. WALLPANELTM is an innovative wall

panel that can provide true R60 Insulation with a mere 6 inches of wall

thickness, any structure constructed with the WALLPANELTM system will

save up to 75% of the energy needed to heat or cool the building.

All this at a lesser total construction cost than standard construction.

MULTICERAMICSTMInsulation coating is a unique one-part coating composed of blend

of nano acrylics and resin additives formula. MULTICERAMICSTM provides R equivalent

"RE" insulation and great surface finish, it has no VOCs, utilizes different types and sizes

of ceramics that block 95% of the sun's

radiant heat visual light, ultra violet rays and

infrared rays. MULTICERAMICSTM is a

permanently flexible "breathing" membrane

that stops water penetration, and prevents

corrosion and surface deterioration with two

additional advantages over other ceramic

coatings. MULTICERAMICSTM has Micro Packing, No Fade, Nano and Cool Touch

technologies. It can save thousands every year in utilities expenses. JUST PAINT AND

SAVE!

ACRYLIC STUCCO is a mixture of high- performance acrylics specially blended for

breath-ability, adhesion, flexibility, texture and toughness.

Added in the formulation is a special ceramic and aggregate

compound to insure a stucco texture surface but with the

added characteristics not found in standard dry mix ratios of

stucco. It is not affected by water or moisture-penetration, and

is designed to stay down for a long bonding life. It will not

crack and peel. It is UV-protected for long life and durability

against weathering whether in hot or cool climates or under

high humidity or very dry. It is tough and durable to provide

years of service and added beauty.

EZ-Hot/Cold CoatingTM will stop condensation of chilled or freezing lines with just a 1/8"

of an inch, this coating is so efficient that can achieve very high insulation at less than

half the thickness required by other insulation coatings.

EZ-Hot/Cold CoatingTM is water borne to offer a non-flammable, no toxicity formula

and zero VOCs for high heat or freezing applications . The Nano technology used in this

coating offers a "micro-packing" set that is required for quick adhesion while at the same

time offering a formulation to immediately calm the heat conduction from the surface of

the pipe to give better adhesion to any surfaces. 

Clear-Coat is produced in two distinctive formats, a single component and a two-part

Nano Technology "0" VOC aliphatic polyurethane enamel that forms a uniquely hard and

durable coating film. This self-leveling coating is resistant to water, acids, solvent and

impact. Clear-Coat is a one-coating system. Clear-Coat can be applied to metal,

concrete, masonry, wood and many other substrates that need UV control, antimicrobial, anti-graffiti, or simply a tough clear coating to enhance and beautify any

surface.

RUSTVACCINETM is a one-part polyurethane coating that contains no VOC's or known

carcinogens. Upon curing, RUSTVACCINETM provides a protective coating of superior

adhesion, flexibility, abrasion- and impact-resistance. It is resistant to most chemical

solvents and acid splash. RUSTVACCINETM can be used as a primer or a stand-alone

coating. RUSTVACCINETM can be tinted to any color and can serve as a finished top

http://www.supertherm.net/ 1/2
 

 

• 

• 

• 

• 

• 

• 

Luxury and Economy Redefined 

2/21/2019 Case 3:20-cv-08190-DWL Document 1-3 Filed 07/28/20 Page 3 of 3 WALLPANEL Corporate Home Page

That is our commitment to the industry. Doing

the right thing for the environment, should not

place demands, instead, it should offer

rewards.

WALLPANEL® can do R-30 walls roofs and

floors with standard 6” thickness, and

increase the R value up to R-60 on the same

6" thickness by coating the finished walls

panels with our MulticeramicsTM insulating

coating.

We call this system SUPERTHERMAL©, The

coating system will last a minimum of 25

years and provide 20 minutes fire proofing

while blocking sound by an additional 68%.

This system can be assembled by a single

person without effort.

SIPs "Structural Insulated Panels" by

definition WALLPANEL® complies with the

description, the main difference is that

WALLPANEL® can be shaped in the field

without loosing it's structural strength or

integrity, any design is possible and easily

achieved with the wall panels, you make the

decision right when is needed, no new

engineering is ever needed.

©Copyright TDE Group SUPERTHERM Inc.

1999,2017

Phones : 

888-887-0144 - 928-443-0685

coat as well as a primer. Can encapsulate other paints and other toxic materials.

RUSTVACCINETM can be applied directly over cleaned flash rust or most firmly bonded

paints. In most cases, no metal blasting is required.

The MARBLE-EMULATION Coating is produced in two distinctive formats, a single

component and a two-part Nano Technology "0" VOC aliphatic polyurethane enamel that

forms a uniquely hard and durable coating film. This self-leveling coating is resistant to

water, acids, solvent and impact. MARBLE-EMULATION is a system. MARBLEEMULATION can be applied to metal, concrete, masonry, wood and many other

substrates UV control, anti-microbial, anti-graffiti, or simply a tough clear coating to

enhance and beautify any surface.

The significant Difference :

WALLPANELTM System, eliminates compliance concerns.

Walls are very fast and easily erected with minimum personnel.

The panels are of the standard 4" or 6" thickness.

The studs are at the standard 16" on center spacing.

The design makes it possible to meet the 16" on center studs and

Trusses at 24" on center without top plates for load distribution.

Pre-cut electrical carriers.

Pre-molded central vacuum lines cavities that are self aligned from panel to panel.

Pre-Molded high velocity heating air condition lines.

No Chlorofluorocarbons, 

Consistent high R 30 - 40 - 60 values without decay.

Meets or exceeds the requirement of all major building codes.

The fastest build up

Uncomplicated efficiency and highest insulation per inch of thickness

No special engineered panels are ever needed

Roof systems for simplicity and incredible sound and insulation comfort

Attic less residential are incredibly easy to install

WALLPANEL is the most economical system available

Contact our offices for a distributor near you.

All other inquires can be made via Email or:

International inquires can be directed to our corporate headquarters by calling 928-776-2910

For dealerships in the United States call our toll free 888-887-0144

Email support@spertherm.net

http://www.supertherm.net/ 2/2
   

Case 3:20-cv-08190-DWL Document 1-4 Filed 07/28/20 Page 1 of 28 

Exhibit C 
 

 

 

 

 

 

 

WALLPANEL Corporate Home Page 

Case 3:20-cv-08190-DWL Document 1-4 Filed 07/28/20 Page 2 of 28 

SUPERTHERM Inc. 

Green Efficiency and Beauty 

Are some of the added benefits Architects, 

Builders and contractors enjoy when 

designing and building with the 

WALLPANELTM wall panel System. 

Any project that includes Energy 

Conservation, Green Points, Speed or 

Budgetary constrains, can be accomplished 

exceeding the highest expectation. 

WALLPANELTM System does not requires 

structural engineering stamps for every 

modification to the wall panels. 

Simplicity and Strength 

It takes cutting 60 or more trees to build a house with wood, that is not 

"Green" WALLPANEL system does not use or need wood. 

The HIGHTHERM R24 - SUPERTHERMTM R30 - or SUPERTHERMAL 

R60 true insulation wall panels designed for commercial and residential 

applications, when conservation is a must this system is designed to 

achieve a super insulated stable structure that makes erecting 

residential building a simple task. WALLPANELTM is an innovative wall 

panel that can provide true R60 Insulation with a mere 6 inches of wall 

thickness, any structure constructed with the WALLPANELTM system 

will save up to 75% of the energy needed to heat or cool the building. 

All this at a lesser total construction cost than standard construction. 

MULTICERAMICSTMInsulation coating is a unique one-part coating composed of 

blend of nano acrylics and resin additives formula. MULTICERAMICSTM provides R 

equivalent "RE" insulation and great surface finish, it has no VOCs, utilizes different 

types and sizes of ceramics that block 95% 

of the sun's radiant heat visual light, ultra 

violet rays and infrared rays. 

MULTICERAMICSTM is a permanently 

flexible "breathing" membrane that stops 

water penetration, and prevents corrosion 

and surface deterioration with two 

additional advantages over other ceramic coatings. MULTICERAMICSTM has Micro 

Packing, No Fade, Nano and Cool Touch technologies. It can save thousands 

every year in utilities expenses. JUST PAINT AND SAVE! 

ACRYLIC STUCCO is a mixture of high- performance acrylics specially blended for 

breath-ability, adhesion, flexibility, texture and toughness. 

Added in the formulation is a special ceramic and aggregate 

compound to insure a stucco texture surface but with the 

added characteristics not found in standard dry mix ratios of 

stucco. It is not affected by water or moisture-penetration, 

and is designed to stay down for a long bonding life. It will 

not crack and peel. It is UV-protected for long life and 

durability against weathering whether in hot or cool climates 

or under high humidity or very dry. It is tough and durable to 

provide years of service and added beauty. 

EZ-Hot/Cold CoatingTM will stop condensation of chilled or freezing lines with just a 

1/8" of an inch, this coating is so efficient that can achieve very high insulation at less 

than half the thickness required by other insulation coatings. 

EZ-Hot/Cold CoatingTM is water borne to offer a non-flammable, no toxicity formula 

and zero VOCs for high heat or freezing applications . The Nano technology used in 

this coating offers a "micro-packing" set that is required for quick adhesion while at 

the same time offering a formulation to immediately calm the heat conduction from 

the surface of the pipe to give better adhesion to any surfaces. 

Clear-Coat is produced in two distinctive formats, a single component and a two-part 

Nano Technology "0" VOC aliphatic polyurethane enamel that forms a uniquely hard 

and durable coating film. This self-leveling coating is resistant to water, acids, solvent 

and impact. Clear-Coat is a one-coating system. Clear-Coat can be applied to metal, 

concrete, masonry, wood and many other substrates that need UV control, antimicrobial, anti-graffiti, or simply a tough clear coating to enhance and beautify any 

surface. 

RUSTVACCINETM is a one-part polyurethane coating that contains no VOC's or 

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l_~ 11111~11\1:r - - --\~_____:___; 

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Lu ury and Ec-0 omy Redefi ed 

WALLPANEL Corporate Home Page 

Case 3:20-cv-08190-DWL Document 1-4 Filed 07/28/20 Page 3 of 28 

That is our commitment to the industry. 

Doing the right thing for the environment, 

should not place demands, instead, it 

should offer rewards. 

WALLPANEL® can do R-30 walls roofs 

and floors with standard 6” thickness, and 

increase the R value up to R-60 on the 

same 6" thickness by coating the finished 

walls panels with our MulticeramicsTM 

insulating coating. 

We call this system SUPERTHERMAL©, 

The coating system will last a minimum of 

25 years and provide 20 minutes fire 

proofing while blocking sound by an 

additional 68%. This system can be 

assembled by a single person without effort. 

SIPs "Structural Insulated Panels" by 

definition WALLPANEL® complies with the 

description, the main difference is that 

WALLPANEL® can be shaped in the field 

without loosing it's structural strength or 

integrity, any design is possible and easily 

achieved with the wall panels, you make the 

decision right when is needed, no new 

engineering is ever needed. 

©Copyright TDE Group SUPERTHERM 

Inc. 

1999,2017 

Phones : 

888-887-0144 - 928-443-0685 

known carcinogens. Upon curing, RUSTVACCINETM provides a protective coating of 

superior adhesion, flexibility, abrasion- and impact-resistance. It is resistant to most 

chemical solvents and acid splash. RUSTVACCINETM can be used as a primer or a 

stand-alone coating. RUSTVACCINETM can be tinted to any color and can serve as a 

finished top coat as well as a primer. Can encapsulate other paints and other toxic 

materials. RUSTVACCINETM can be applied directly over cleaned flash rust or most 

firmly bonded paints. In most cases, no metal blasting is required. 

The MARBLE-EMULATION Coating is produced in two distinctive formats, a single 

component and a two-part Nano Technology "0" VOC aliphatic polyurethane enamel 

that forms a uniquely hard and durable coating film. This self-leveling coating is 

resistant to water, acids, solvent and impact. MARBLE-EMULATION is a system. 

MARBLE-EMULATION can be applied to metal, concrete, masonry, wood and many 

other substrates UV control, anti-microbial, anti-graffiti, or simply a tough clear 

coating to enhance and beautify any surface. 

The significant Difference : 

WALLPANELTM System, eliminates compliance concerns. 

Walls are very fast and easily erected with minimum personnel. 

The panels are of the standard 4" or 6" thickness. 

The studs are at the standard 16" on center spacing. 

The design makes it possible to meet the 16" on center studs and 

Trusses at 24" on center without top plates for load distribution. 

Pre-cut electrical carriers. 

Pre-molded central vacuum lines cavities that are self aligned from panel to panel. 

Pre-Molded high velocity heating air condition lines. 

No Chlorofluorocarbons, 

Consistent high R 30 - 40 - 60 values without decay. 

Meets or exceeds the requirement of all major building codes. 

The fastest build up 

Uncomplicated efficiency and highest insulation per inch of thickness 

No special engineered panels are ever needed 

Roof systems for simplicity and incredible sound and insulation comfort 

Attic less residential are incredibly easy to install 

WALLPANEL is the most economical system available 

Contact our offices for a distributor near you. 

All other inquires can be made via Email or: 

International inquires can be directed to our corporate headquarters by calling 928-776-2910 

For dealerships in the United States call our toll free 888-887-0144 

Email support@spertherm.net 

http://www.supertherm.net/[2/26/2019 5:16:36 PM] 
 

 

 

 

t1I 

REFLECTIVITY 

 No Fade C.oatlng 

 Conventional Paint 

Multi-Ceramics Techsheet Page 

Case 3:20-cv-08190-DWL Document 1-4 Filed 07/28/20 Page 4 of 28 

SUPERTHERM Inc. 

TECH SHEET 

High Tech Ceramics Insulation Navigate Our Site 

Industrial & Residential 

PHYSICAL DATA: 

Solids: By weight 60.6% / By 

volume 68%. 

Film Thickness: On all substrates 

MULTICERAMICSTM should be applied 

at 10 mils wet / 7 mils dry. Under no 

circumstances should 

MULTICERAMICSTM be applied at less 

than 7 mils dry. 

Dry Time: One hour to touch at 70F. 

degrees and bright sun / Overcoat 

window is two hours or longer at 70F. 

degrees / Fully cures in two days. 

Lead and chromate free.

 Cures by evaporation with no cosolvents present. 

Weight: 6 lbs. per gallon. 

Shelf Life: up to 2 years (unopened) 

under appropriate storage conditions 

(see MSDS). 

VOC Level: 0 grams/liter. 

pH: 8.5 - 9.0. * Viscosity: 

100-105 KU. 

INSULATING WITH A SINGLE COAT 

NO THICKER THAN A BUSINESS CARD 

RUSTVACCINE penetrates and locks in 

to encapsulate rust, land paint paint, 

and other hazardous materials found in 

and around building structures. The 

danger associated with inhaling or 

ingesting these particles can be totally 

eliminated. RUSTVACCINE also has 

the ability to encapsulate substrates 

prone to mold and mildew without 

adding VOCs or dangerous chemicals 

to the environment in the process, this 

reduces cost in preparation and 

disposals, maintaining safety and 

contamination concerns in full control. 

©Copyright TDE Group 

SUPERTHERM Inc. 

1999,2011 

Phones : 

888-887-0144 - 928-443-0685 

DESCRIPTION: 

MULTICERAMICSTM is a unique one-part coating composed of blend of nano acrylics, and resin additives formula. 

MULTICERAMICSTM utilizes different types and sizes of ceramics that block 95% of the sun's radiant heat visual light, ultra violet 

rays and infrared rays. MULTICERAMICSTM is a permanently flexible "breathing" membrane that stops water penetration, and 

prevents corrosion and surface deterioration with two additional advantages over other ceramic coatings. 

MULTICERAMICSTM No Fade and Cool Touch technologies. 

TYPICAL USES:

 As a one-coat insulation system on exterior and interior substrates (roofs, walls, and floors)

 As an insulator for transportation vehicles, refrigerated containers, and railroad cars

 As insulation and to stop condensation on HVAC systems, tanks, and storage systems

 As a one-coat "flexible and breathable" protective system over metal, concrete, masonry, and wood to stop water penetration 

and corrosion, resist dirt, mold, mildew, and pollution, increase longevity, and reduce surface maintenance

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

Product Application and Handling MULTICERAMICSTM 

APPLICATION METHODS: 

MULTICERAMICSTM 

can be applied to metal, concrete, masonry, and wood. The application can be by spray, brush, or roller. For specific 

instructions on surface preparation, mixing, and application, please refer to the application instructions for 

MULTICERAMICSTM 

SAFETY PRECAUTIONS: 

Do not use this product without first taking all appropriate safety measures to prevent property damage 

and injuries. These measures may include, without limitation: proper ventilation, use of proper lamps, 

wearing of protective clothing and masks, tenting, and proper separation of application areas. 

IMPORTANT: 

Metal structures should be primed with RUSTVACCINE before applying MULTICERAMICSTM can be applied by brush, roller 

or spray equipment. It should be applied evenly without buildup. Apply in a 2-coat application system of 8 mils each. 

CAUTION: As with any spray-able you should wear gloves and protective clothing. 

KEEP OUT OF REACH OF CHILDREN. 

For more specific safety procedures, please refer to 

the MULTICERAMICSTM Material Safety Data Sheet. 

LIMITATION OF LIABILITY: The information contained in this data sheet is based upon tests that we believe to be accurate and is 

intended for guidance only. All recommendations or suggestions relating to the use of the products made by WALLPANEL, whether in 

technical documentation, or in response to a specific enquiry, or otherwise, are based on data which to the best of our knowledge is 

reliable. The products and information are designed for users having the requisite knowledge and industrial skills, and the end-user has 

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

WALLPANEL has no control over either the quality of condition of the substrate, or the many factors affecting the use and application of 

the product. 

Therefore, WALLPANEL does not accept any liability arising from loss, injury, or damage resulting from such use or the contents of this 

data sheet (unless there are written agreements stating otherwise). 

The information contained in this data sheet is subject to modification as a result of practical experience and continuous product 

development. This data sheet replaces and annuls all previous issues and the user has the responsibility to ensure that this sheet is 

current prior to using the product. 

http://www.supertherm.net/mc1_techsheet.htm[2/26/2019 5:17:38 PM] 
Quality Without Compromise 

Multi-Ceramics Techsheet Page 

Case 3:20-cv-08190-DWL Document 1-4 Filed 07/28/20 Page 5 of 28 

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, , .. ' 

No Fade Acrylic Stucco 

No Fade Tl.I Color Retention 

Clear Coatings 

High Temperature Coatings 

Corrosion Encapsulalion 

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Acrylic Stucco 

Case 3:20-cv-08190-DWL Document 1-4 Filed 07/28/20 Page 6 of 28 

Efficiency and Beauty 

Are some of the added benefits 

Architects, Builders and contractors 

enjoy when designing and building with 

the WALLPANELTM System. 

Any project that includes Energy 

Conservation, Green Points, Speed or 

Budgetary constrains, can be 

accomplished exceeding the highest 

expectation. WALLPANELTM 

System does not requires structural 

engineering stamps for every 

modification to the panels. 

Simplicity and Strength 

That is our commitment to the industry. 

PRODUCT DESCRIPTION: 

ACRYLIC STUCCO is a mixture of high- performance acrylics specially blended for breath-ability, adhesion, flexibility, texture and 

toughness. Added in the formulation is a special ceramic and aggregate compound to insure a stucco 

texture surface but with the added characteristics not found in standard dry mix ratios of stucco. It is not 

affected by water or moisture-penetration, and is designed to stay down for a long bonding life. It will not 

crack and peel. It is UV-protected for long life and durability against weathering whether in hot or cool 

climates or under high humidity or very dry. It is tough and durable to provide years of service and added 

beauty. 

ACRYLIC STUCCO 

was designed with "0" VOC's and no known carcinogens to coat a variety of surface structures on metal, 

wood, stone, concrete, fiberglass or composites without health concerns. If the quantity is a minimum of 300 

gallons, ACRYLIC STUCCO can be batched in an assortment of colors as desired to beautify a home's appearance while providing a 

very attractive, durable surface to the wail structure for years of service. It breathes, and, unlike standard stucco, it can flex with the 

substrate without cracking giving years of maintenance-free service. Due to the blend of acrylics, 

ACRYLIC STUCCO will not allow water to penetrate that can affect and damage substrates. It has added mildewcide in the formula 

to guard against the growth. When top coated with Multi-Ceramic RE19 Coating for insulation, the surface provides an insulating 

effectiveness equal to R-equivalency of 19 on the exterior walls and will not cover the stucco texturing. 

APPLICATION METHODS: 

Surfaces must be clean and dry before application. Any loose or flaking old paints or corrosion must be removed from the surfaces 

before applying. High pressure water-blasting (3500 psi) is as effective as light sand-blasting in removing loose or flaking surfaces. As 

a rule, "a coating is only as good as the surface it covers." Grease, oil, waxy substances, dirt, etc. must be cleaned from surfaces. Oil 

paints can remain if bonded solidly to surfaces. 

ACRYLIC STUCCO 

can be applied by a Graco Model 1030, 5-horse, airless sprayer or air pot sprayer, or trowel. Spraying requires a steel carbon tip of 

sires .064 or larger, if desired 

IMPORTANT: 

Do not take internally. Avoid contact with eyes. If solution does come in contact with eyes, flush immediately with water and contact a 

physician for medical attention. For quickest removal from skin, wash with water before drying. 

The significant Difference : 

Coating thickness: At 20 sq.ft./gallon: 64 dry mils (1/16 inch) 

Dry time: to touch - 12 hours to recoat - overnight 

Full cure - 7 days at 75 degrees Fahrenheit/ 50% relative humidity 

Percent solid: 70% by volume 

VOC: "0" lb./gallon Weight per gallon: 16.5 lbs. 

Weight per gallon: 16.5 lbs. 

Clean up: Soap and water for both person and equipment 

SURFACE COVERAGE: 20 sq.ft. per Gallon 

The fastest build up single coat finish 

Uncomplicated efficiency and longer lasting system 

UV controlled to minimize aging and cracking 

Interior and exterior finishes available 

Moisture resisting in all weather conditions 

Incredible color retention that remains looking new for many years 

http://www.supertherm.net/acrylic.htm[2/26/2019 5:17:45 PM] 
 

Luxury and Economy Redefined 

Acrylic Stucco 

Case 3:20-cv-08190-DWL Document 1-4 Filed 07/28/20 Page 7 of 28 

Doing the right thing for the 

environment, should not place 

demands, instead, it should offer 

rewards. 

©Copyright TDE Group 

SUPERTHERM Inc. 

1999,2008 

Phones : 

888-887-0144 - 928-443-0685 

Contact our offices for a distributor near you. 

All other inquires can be made via Email or: 

International inquires can be directed to our corporate headquarters by calling 928-776-2910 

For dealerships in the United States call our toll free 888-WALLPNL (888-925-7265). 

Email support@wallpanel-systems.com 

http://www.supertherm.net/acrylic.htm[2/26/2019 5:17:45 PM] 
 

 

 

 

C Multi-Ceramics Insulation Coating RE 19 

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No Fade TM Color Retention 

Clear Coatings 

High Temperature Coatings 

Couos1on Enc.apsulation 

Multi-Ceramics Insulation 

Case 3:20-cv-08190-DWL Document 1-4 Filed 07/28/20 Page 8 of 28 

R Equivalent INSULATION COATING THAT REALLY WORKS! 

Technology for Energy Conservation 

MULTICERAMICS outperform other insulation Now you have the information! Stopping climate 

coatings: change starts with you today, because it takes less 

R Equivalence with a 0.007 coat (Interior App.) With NO FADE 

and Cool Touch Technology 

resources to conserve 40% of the energy production, 

than to build the infrastructure to produce 40% more 

R Equivalence with just 0.007 coat energy. 

Sound Blockage 

MultiCeramicsTM Technology line 

Outperforms Energy Star Best 

Surpases California Cool Roof Program 

Tested better overall than the most expensive options 

Works on Interior/Exterior 

Class "A" Rated "0" Flame Spread 

Passed 5000 hours Salt spray tests 

USDA Approved 

Water Proof (Not just water resistant) 

Blocks 99.5% of Infrared 

Resists Mold & Mildew 

25 Years residential life expectancy 

K value (0.07) ASTM Testing 

PAY BACK RATIO TO INVESTMENT: 

Solar photovoltaic systems : 5 to 20 years 

Appliances: 10 + years 

Weatherization: 20 years 

MULTICERAMICS: 1 1/2 year 

MultiCeramicsTM Is a TECHNOLOGY! 

Do The Math! Built with a blend of nano acrylics and 

polymers, which makes it flexible, yet 

tough It has Multi- ceramics technology 

to give not only reflective abilities but 

also non-conductive ability for heat and 

cold. Other electrometric reflective 

coatings as well as the many "ADD 

ON CERAMICS to cheap paint" type, 

have only one acrylic and a single 

reflective ceramic. MultiCeramicsTM 

ceramics are not the rough 

http://www.supertherm.net/multicera.htm[2/26/2019 5:17:53 PM] 
 

 

Criteria for solar reflectance: 

Flat and Low Slope Initial solar After 3rd Year After 10 

Roof pitch reflectance solar reflectance years 

Energy Star: =or< 2:12 65% 50% Not rated 

EZ Cool Roof: = or < 2:12 82.2% 78.2% ·?4% 

Multi-Ceramics Insulation 

Case 3:20-cv-08190-DWL Document 1-4 Filed 07/28/20 Page 9 of 28 

MULTICERAMICSTM Really works! 

MicroPacking Vs. Plating 

MultiCeramicsTM technology provides corrosion protection and "MicroPacking" that reduces surfaces maintenance many times the normal life span of any application, it saves 

energy, provides longer life to properties and surfaces. Unlike the alternative fiberglass or foams, it poses no health hazards and offers greater comfort by outperforming all others 

under most conditions. MultiCeramicsTM is the ultimate insulation material. 

Chemically Different 

MultiCeramicsTM EZ Cool Roof System unique performance characteristics are based on a polymer chemistry that is amorphous, rather than crystalline, 

in nature. Crystalline liquids dry to a bed of thousands of tiny individual crystals, which can separate under maintenance traffic, temperature variations, 

or normal building flexion. Amorphous chemistries process a random molecular structure, drying to a fibrous, continuous film, with 25 times the elasticity 

of fiberglass felt. 

High Strength to Weight 

The MultiCeramicsTM Superior Roofing System was developed with space age characteristics-unusual strength combined with weight that is up to 90% 

less than competing products. Combining a penetrating base coat with the spun-bond, continuous-filament polyester backbone fabric POLYFAB weighing 

multifaceted type as the one found in 

other coatings, 

MultiCeramicsTM ceramics are 

specially manufactured. The unique 

size, types and shapes permits the 

ceramics to settle very tight together 

and not allowing air to interact between 

the ceramics producing the "Micro 

Packing" effect, this far surpasses 

older technology. 

Proving-Ground Tough 

While MultiCeramicsTM is a space age 

chemical formulation, it is a fully tested 

product. It was derived after carefully 

http://www.supertherm.net/multicera.htm[2/26/2019 5:17:53 PM] 
 

 

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1000 12'(1 1500 

_..,..,.. 

REFLECTIVITY 

 No Fade c.oatfng 

 Conventional Paint 

Multi-Ceramics Insulation 

but 2.2 oz/sq. yd. (75 gr/m)- the complete system including reflective topcoat is no thicker than a dime, yet is strong enough to support a footprint-sized Case 3:20-cv-08190-DWL Document 1-4 Filed 07/28/20 Page 10 of 28 

weight in excess of 3500 pounds (1589 kg) before bursting. 

Dimensional Stability 

MultiCeramicsTMEZ Cool Roof System when bent, returns to its precise linear dimensions within a ± tolerance. It remains 99% dimensionally stable 

throughout its useful life. This linear flexing without cracking or dimensional changes facilitates MultiCeramicsTM installation around cooler bases, exhaust 

chimneys and up parapets, and assures a continuous self-flashing, weather resistant seal over the entire roof's surface. 

Fire Resistant 

The MultiCeramicsTM Superior Roofing System offers an additional benefit to commercial and residential users in dry or fire-prone areas. While no 

lightweight roofing material is fireproof, MultiCeramicsTM has no flash point. Should an outside flame be applied directly to the roof's surface, the material 

itself will deteriorate, but will not ignite. 

Embrittling-Resistant 

After years in the sun, or of enduring climatic extremes, petroleum-based roofing matter can become brittle, and crack. MultiCeramicsTM has been 

formulated specifically to withstand the searing heat of the Arizona deserts while retaining inherent structural flexibility. To date, industrial and residential 

applications have undergone in excess to 105,120 hours of continuous exposure to the desert climate, including day/night temperature variations of 60 

degrees (16o C) without failure and without embrittling. 

Water Proof NOT "Moisture Proof" 

The MultiCeramicsTM EZ Cool Roof System continuous-filament, single-ply, fluid applied superior roofing system provides one of the most efficient longlife moisture barriers available in the industry today, with a moisture-vapor transmission rate of just 0.94 perms per mil. 

No Added Plasticizers or Flame Retardants 

The flexible, non-combustive qualities of the MultiCeramicsTM, Superior Roofing System are inherent in the product's chemical formulation, and remain 

properties of the cured film throughout its life. Some competitive coatings contain plasticizers and flame retardant additives, which leach out over time, 

causing the coating to become brittle and crack, permitting moisture to penetrate substrate materials. 

Long Life, Little Labor 

Direct roofing costs can be divided into two categories, materials and labor. Labor traditionally Constitutes the greater percentage of such costs. 

MultiCeramicsTM EZ Cool Roof System was designed to reduce labor costs by: 

1) Permitting application by unskilled labor, with hand tools only. 

2) Lasting longer than ordinary roofs. 

3) Its ability to be applied over virtually any sound old-roof surface, without expensive tear-off procedures. 

4) Its inherent ease of maintenance. Should wear of surface fissures occur for any reason, they are readily repaired by one individual with a container of MultiCeramicsTM, a paint 

brush and POLYFAB fabric. 

Energy Savings 

Traditional roofs do more than divert the elements. In the past, they have also served as heat sinks, absorbing the sun's heat and redistributing it throughout building interiors-to the 

distress of occupants and the delight of utility companies. MultiCeramicsTM was formulated as both insulator and reflector designed to maintain comfortable interior temperatures at 

reduced utility cost. Formal testing indicates a solar reflectance for the product of 82.2%, more than three times greater than gravel-coat asphalt. As a result interior temperatures 

are reduced by up to 30oF (17o C) and roof expansion and contraction are held to minimum. In addition to this uniquely high reflectance capability, the MultiCeramicsTM Superior 

Roofing System features an insulating factor only slightly less than products up to 20 times its thickness. MultiCeramicsTM roofs have reduced interior temperatures by as much as 

30 degrees in retrofit applications. Should design requirements dictate, the product is available in the full spectrum of colors. Reflective characteristics will vary with the color 

http://www.supertherm.net/multicera.htm[2/26/2019 5:17:53 PM] 

documenting the performance 

characteristics of countless individual 

compounds. It has been "torturetested" by such unusual applications 

as water pool walls and hot muffler 

patches. It has been proven in actual 

use throughout the United States and 

abroad under the most rigorous 

climatic conditions, and tested effective 

from subfreezing to searing desert 

temperatures. When used according to 

factory recommendations, it simply do 

not fail. 

©Copyright TDE Group 

SUPERTHERM Inc. 

1999,2008 

Phones : 

888-887-0144 - 928-443-0685 
Multi-Ceramics - True Space Age Insulation Coating 

Multi-Ceramics Insulation 

Case 3:20-cv-08190-DWL Document 1-4 Filed 07/28/20 Page 11 of 28 density selected. Check with your MultiCeramicsTM representative for specific information. 

http://www.supertherm.net/multicera.htm[2/26/2019 5:17:53 PM] 
 

 

 

C Multi-Ceramics Insulation Coating RE19 

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Mull~Ceram1c Coating RE19 

No Fade Acrylic Stucco 

·No Fade n.l Color Retention 

Clear Coatings 

· High Temperature Coatings_ 

Corrosion Encapsulation 

Marble Emulation Coat 

Email Support 

Multi-Ceramics Insulation 

Case 3:20-cv-08190-DWL Document 1-4 Filed 07/28/20 Page 12 of 28 

NO-FADE COATING

 NO-FADE COATING Technology for Energy Conservation 

Features : 

Virtually No Odor 

Exceptional Flow 

0 VOC 

Nano Technology line 

Splatter Free 

Hypo-Allergenic 

Netonian Rheology 

Virtually No Sag 

One Coat Hide Technology 

Brush, Roll or Spray 

No-Fade Coating is one of the first water based acrylic urethanes, Dries Rapidly 

which has been formulated especially for chemically sensitive people Moisture resistant 

and professional painters. No Known Carcinogens or Neurotoxins It is odor free, No-Fade Coating Does NOT Contain any known 

Resists Mold & Mildew 

hazardous toxic or carcinogenic materials such as benzene, ethylene 

Water Cleanup glycol, volatile organic compounds, neurotoxins, lead, mercury, 

10 Years residential no-fade color formaldehyde, heavy metals, or phthalates which can burn eyes and 

International Codes Council Approved nose, cause headaches, or nausea. 

Ecological friendly EXTERIOR 

INTERIOR 

NoFADE© Is a PAINT! Built with nano 

technology that contains "0" VOC's flexible, 

yet tough It has NoFADE© and cool touch 

technology built in to give not only reflective 

abilities but also extreme color retentiona nd 

UV stability. NoFADE© ceramics are not the 

rough multifaceted type as the one found in 

other coatings, NoFADE© ceramics are 

designed to form "Micro Packing" for 

extreme color retention even dark colors in 

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237 

239 

227 228 229 

230 231 

236 

233 234 

Cool Touch 

Technology 

COLORS INSPIRED BY 

MOTHER NATURE 

Multi-Ceramics - True Space Age Insulation Coating 

Multi-Ceramics Insulation 

Case 3:20-cv-08190-DWL Document 1-4 Filed 07/28/20 Page 13 of 28 

extreme weather environments. 

NoFADE© coating is formulated for interior 

or exterior applications is nearly odorless and 

dries in one our for a great look, on interior it 

will not emit gases or odor leaving a 

comfortable clean feeling. 

MultiCeramics© technology provides corrosion protection and "micro packing" that reduces surfaces maintenance for 3 to 4 times the normal life span of any application, it 

saves energy, provides longer life to properties and surfaces. It poses no health hazards and offers greater comfort by outperforming all others under most conditions. 

MultiCeramics© is the ultimate formulation material. 

©Copyright TDE Group SUPERTHERM Inc. 

1999,2008 

Phones : 

888-887-0144 - 928-443-0685 

http://www.supertherm.net/nofade.htm[2/26/2019 5:18:54 PM] 
 

 

 

 

 

-~ 

No Fade Acrylic Stu;;co 

No Fade TM Color Retention 

Clear Coatings 

High Temperature Coatings 

Corro51on Encapsulation 

Marble E mutahon Coat 

Email Support 

Th_ ':lea_r Advantag~ 

Uniquely Hard and Durab' e 

R.esistant to Water Stains 

Resists Solvents & Chemicals 

Graffiti-Proof Clear Coat"ng 

Spray - Roll - Brush 

Interior or Exterior Application 

WALLPANEL Corporate Home Page 

Case 3:20-cv-08190-DWL Document 1-4 Filed 07/28/20 Page 14 of 28 

SUPERTHERM Inc. 

Efficiency and Beauty 

Are some of the added benefits 

Architects, Builders and contractors 

enjoy when designing and building with 

the WALLPANELTM System. 

Any project that includes Energy 

Conservation, Green Points, Speed or 

Budgetary constrains, can be 

accomplished exceeding the highest 

expectation. WALLPANELTM 

System does not requires structural 

engineering stamps for every 

modification to the panels. 

Simplicity and Strength 

CLEAR-COAT is a tough, fast curing, single or two component polyurethane 

enamel, which produces a uniquely hard and durable coating film. CLEAR-COAT will demonstrate 

unsurpassed semi gloss retention, color retention, and chalk resistance, when utilized for exterior 

coating situations. CLEAR-COAT will provide outstanding resistance to water and humidity, stains, 

chemicals, and solvents, as well as tremendous scuff, mar, and impact resistance. Ideal for use on 

bridges applied by itself, or over other finishes for complete encapsulation of the metal, providing 

protection from rust and corrosion for a minimum of 20 years in normal circumstances. Resistant to 

hail damage and similar abuses that create opportunities for rust and corrosion. Completely UV- controlled and weather resistant. 

CLEAR-COAT is a self leveling formula for an outstanding finish. CLEAR-COAT can be used on flooring for a tough, long wearing 

surface surfaces must be completely clean and free from moisture and residues to allow the coating to adhere. In summary, the 

overall toughness, durability, and weather resistance of CLEAR-COAT polyurethane enamels, make them the ideal choice for 

demanding product applications for architectural maintenance that require the utmost in exterior durability. CLEAR-COAT is an 

ambient fast cure coating. 

Other Uses For This Coating 

RAFFITI-PROOF RESISTANCE: 

After CLEAR-COAT has been applied and allowed to cure for at least 5 days, applications of "Krylon" spray paint, Magic Markers, 

etc. can be wiped off conpletely with graffiti cleaner. The color white may show a slight shadow but all dark colors are completely 

clear of graffiti markings. CLEAR-COAT can withstand years of graffiti removal as it is not affected by solvents and does not breathe 

to allow spray paints or oils to penetrate its surface. Because of CLEAR-COAT's Nano technology chemistry and hardness provides 

penetration deep into a substrate for extreme adhesion, it has been used to strengthen and seal concrete and brick walls. 

The significant Difference : 

For use on bridges 

Heavy equipment 

Flooring 

Petroleum valves 

Around salt air 

Or anywhere else there may be a more caustic environment 

Can be ordered in most any color 

Graffiti-Proof clear coat. 

No VOCs 

UV Controlled 

Urethane Tough 

Anti-Microbial Anti-Graffiti All Surfaces 

http://www.supertherm.net/floorcoat.htm[2/26/2019 5:19:01 PM] 
 

Luxury and Economy Redefined 

WALLPANEL Corporate Home Page 

Case 3:20-cv-08190-DWL Document 1-4 Filed 07/28/20 Page 15 of 28 

That is our commitment to the industry. 

Doing the right thing for the 

environment, should not place 

demands, instead, it should offer 

rewards. 

©Copyright TDE Group 

SUPERTHERM Inc. 

1999,2008 

Phones : 

888-887-0144 - 928-443-0685 

Contact our offices for a distributor near you. 

All other inquires can be made via Email or: 

International inquires can be directed to our corporate headquarters by calling 928-776-2910 

For dealerships in the United States call our toll free 888-WALLPNL (888-925-7265). 

Email support@wallpanel-systems.com 

http://www.supertherm.net/floorcoat.htm[2/26/2019 5:19:01 PM] 
 

 

 

 

dvantage 

HEAT-COAT 

Case 3:20-cv-08190-DWL Document 1-4 Filed 07/28/20 Page 16 of 28 

SUPERTHERM Inc. 

Efficient Insulation 

EZ-Hot/Cold CoatingTM is a unique combination of high performance specially designed 

high temperature resins in a water borne formula. This coating will dry in 24 hours and can 

be aided in the dry down by adding high heat to the environment. EZ-Hot/Cold CoatingTM 

was built to be applied over hot surfaces to achieve immediate adhesion while calming 

down the hot surface, or over condensing pipes to stop the condensation. Using this coating 

as the primer and finish coat, we can achieve adhesion over the hot surface and create a 

surface that can be insulated to stop the loss of heat or heat gain on freezing lines, 

EZ-Hot/Cold CoatingTM will stop condensation of chilled or freezing lines with just a 1/8" of 

an inch, this coating is so efficient that can achieve very high insulation at less than half the 

thickness required by other insulation coatings. 

EZ-Hot/Cold CoatingTM is water borne to offer a non-flammable, no toxicity formula and 

zero VOCs for high heat or freezing applications . The Nano technology used in this coating 

offers a "micro-packing" set that is required for quick adhesion while at the same time 

offering a formulation to immediately calm the heat conduction from the surface of the pipe 

to give better adhesion to any surfaces. 

APPLICATION METHODS 

Surfaces must be clean and dry before application. Loose or flaking old 

paints or corrosion must be removed from surface before applying. Surface 

must be clean of all residues and debris. Surfaces can be cleaned by power 

washing the surfaces or sandblasted as a “brush blast or sweep-blast”. This 

coating can best be applied by using a 5 horsepower 2 1⁄2 gallon per minute 

airless sprayer at 3000 psi (.65tip) or hopper gun. Apply a tin coat as the 

primer over the hot surface, first to lock down and reduce the surface heat. 

Wait 15 minutes and apply to the thickness needed for heat reduction 

desired. If outside, overcoat with our top coat for weather and UV protection. 

Allow to dry one hour before re-coating. This is a water-based coating. 

Never apply if raining or chance of rain the day of application. EZ-Hot/Cold 

CoatingTM Is a thick coating that is applied in various simple methods. It 

does not swell and become fragile heating process. fights the appearance 

of condensation on its surface by the reaction of the ceramics. It is a natural 

corrosion-, fungus/mildew- resistant coating when not in operation against a 

fire. 

IMPORTANT 

Do not take internally. Avoid contact with eyes. If solution does come 

in contact with eyes, flush immediately with water and contact a 

physician for medical attention. Avoid prolonged contact with skin or 

breathing of spray mist. For quickest removal from skin, wash with 

water before drying. ALL filters must be removed to prevent sifting 

of ceramic particles. 

http://www.supertherm.net/heatcoat.htm[2/26/2019 5:19:07 PM] 
 

 

Luxury and Economy Redefined 

HEAT-COAT 

Case 3:20-cv-08190-DWL Document 1-4 Filed 07/28/20 Page 17 of 28 

Designing hot water distribution systems 

with EZ-Hot/Cold CoatingTM. Any 

project that includes Energy 

Conservation, Green Points, Speed or 

Budgetary constrains, can be 

accomplished exceeding the highest 

expectation. 

EZ-Hot/Cold CoatingTM System does 

insulation for extreme conditions from 

-50F to 600F 

Simplicity 

That is our commitment to the industry. 

Doing the right thing for the 

environment, should not place 

demands, instead, it should offer 

rewards. 

©Copyright TDE Group 

SUPERTHERM Inc. 

1999,2008 

Phones : 

888-887-0144 - 928-443-0685 

The significant Difference

 75.2@ solids volume.

 60.3% solid by weight

 3 pounds per gallon

 Dry-time: 15 minutes over hot surface, build up as needed 24 hours to fully dry.

 Spread:20 sq.ft. per gallon, giving 60 mil thickness

 Elongation:95%

 pH:8.5-9.0

 ZERO VOCs

 U.S.D.A. approved 

Contact our offices for a distributor near you. 

All other inquires can be made via Email or: 

International inquires can be directed to our corporate headquarters by calling 928-776-2910 

For dealerships in the United States call our toll free 888-WALLPNL (888-925-7265). 

Email support@wallpanel-systems.com 

http://www.supertherm.net/heatcoat.htm[2/26/2019 5:19:07 PM] 
 

 

 

 

 

Corro ion 

Abatament 

ome '------' 

RustVaccine 

Case 3:20-cv-08190-DWL Document 1-4 Filed 07/28/20 Page 18 of 28 

SUPERTHERM Inc. 

Corrosion - Lead and Asbestos Encapsulation Navigate: 

Oil Rigs Mantainance 

RUSTVACCINE is an easy to use, 

cutting-edge, one component 

coating that stops the progression 

of rust and corrosion, and protects 

the substrate far longer than 

conventional, industrial grade rust 

inhibitors. RUSTVACCINE is a 

uniquely designed, urethane 

coating that cures to an extremely 

hard, yet flexible surface resistant 

to acids and salts. The minimal 

preparation does not require a 

white sand blast which saves 

thousands of dollars wasted in man 

hours, equipment, and materials. 

Upon application, RUSTVACCINE 

penetrates deep into the pores of a 

surface anchoring in and actually 

becoming part of the substrate 

itself. This unique ability, combined 

with its excellent abrasion 

resistance, creates a system 

providing unequaled protection 

against surface rust and corrosion. 

ABATING and PROTECTING 

STEEL and other MATERIALS 

RUSTVACCINE penetrates and 

locks in to encapsulate rust, older 

paints, mold, and other hazardous 

materials found in and around 

building structures. The danger 

associated with inhaling or 

ingesting these particles can be 

totally eliminated. RUSTVACCINE 

also has the ability to encapsulate 

substrates prone to mold and 

mildew. 

©Copyright TDE Group 

SUPERTHERM Inc. 

1999,2008 

Phones : 

888-887-0144 - 928-443-0685 

RUSTVACCINE is a one-part polyurethane coating that contains "0" 

VOC's and no known carcinogens. Upon curing, RUSTVACCINE 

provides a protective coating of superior adhesion, flexibility and 

abrasion/impact-resistance. It is resistant to chemical solvents and acid 

splash. Originally designed for metal surfaces, RUSTVACCINE 

demonstrates excellent adhesion to wood, concrete, fiberglass and 

many other substrates. RUSTVACCINE is designed for the 

encapsulation of and adherence to tightly-bonded surfaces of leadbased and other toxic paints as well as rusted surfaces. This unique 

ability is accomplished by the curing mechanism of the base polymer. 

The coating (having a low initial viscosity) wets the rusty surface, then 

penetrates to the foundation of the rust's origin where curing begins. 

RUSTVACCINE is highly recommended as a base coat for 

MULTICERAMICS Insulation Coating. No pot life, no catalyzation, no 

two-part mixing. Can substitute for zinc-rich primer requiring no white 

sand-blasting. Can be applied over rusted surfaces after loose/flaking 

material Is is removed. Dries in one hour and completly cures in 24 

hours. 

Product Application and Handling 

APPLICATION 

Can power wash with solvent wipe down, light commercial blast, or 

power hand tool to remove loose flake and debris before applying. 

Can use power tool (within the guidelines of Clean Air Act) with 

vacuum to prep lead-based paints (as discussed at Steel Structures 

Painting Council--SSPC--. meeting March 15-17 attended by EPA 

and NIOSH) before applying RUSTVACCINE over rust or other 

paints. Possible alternative to abatement of other paints. Surfaces 

should be clean, dry and sound. Existing surface dirt, oil, tar, grease 

and film should be removed from surface by approved methods 

(TSP-Tri-Sodium Phosphate or equivalent) prior to application of 

RUSTVACCINE. MUST BE COMPLETELY DRY. 

IMPORTANT: 

Stir product thoroughly before using. RUSTVACCINE can be applied 

by brush, roller or spray equipment. It should be applied evenly 

without buildup. Apply in a 2-coat application system. CAUTION: 

Wear gloves and protective clothing. Extremely tough to clean off 

skin. Throw away brushes and rollers after use. Wear eye 

protection. Clean-up: For reduction, use water. If sprayed, keep 

water ready to clean equipment before breaks (lunch hour) or at 

conclusion of job. 

RUSTVACCINE 

COMPATIBLE With 

D 4060 1000 Cycles Tabor 

Abrasion 

5000 Hours Weathering 

- Aging: Interior and Exterior 

- Tensile Properties 

D 1308 Chemical Resistance 

D 2794 Direct Impact Resistance 

D 1653 Water Vapor Transmission 

E 84 Surface Burn "0" Spread 

D 3273 Mildew Resistance 

G 85 1500 Hours Salt Fog 

Prohesion Boiling Water 

Encapsulation of rust and other 

Paints Testing: 

http://www.supertherm.net/corrosion.htm[2/26/2019 5:20:08 PM] 
Quality Without Compromise 

RustVaccine 

Case 3:20-cv-08190-DWL Document 1-4 Filed 07/28/20 Page 19 of 28 

http://www.supertherm.net/corrosion.htm[2/26/2019 5:20:08 PM] 
 

 

 

 

 

 

 

WALLPANEL Corporate Home Page 

Case 3:20-cv-08190-DWL Document 1-4 Filed 07/28/20 Page 20 of 28 

SUPERTHERM Inc. 

Green Efficiency and Beauty 

Are some of the added benefits Architects, 

Builders and contractors enjoy when 

designing and building with the 

WALLPANELTM wall panel System. 

Any project that includes Energy 

Conservation, Green Points, Speed or 

Budgetary constrains, can be accomplished 

exceeding the highest expectation. 

WALLPANELTM System does not requires 

structural engineering stamps for every 

modification to the wall panels. 

Simplicity and Strength 

It takes cutting 60 or more trees to build a house with wood, that is not 

"Green" WALLPANEL system does not use or need wood. 

The HIGHTHERM R24 - SUPERTHERMTM R30 - or SUPERTHERMAL 

R60 true insulation wall panels designed for commercial and residential 

applications, when conservation is a must this system is designed to 

achieve a super insulated stable structure that makes erecting 

residential building a simple task. WALLPANELTM is an innovative wall 

panel that can provide true R60 Insulation with a mere 6 inches of wall 

thickness, any structure constructed with the WALLPANELTM system 

will save up to 75% of the energy needed to heat or cool the building. 

All this at a lesser total construction cost than standard construction. 

MULTICERAMICSTMInsulation coating is a unique one-part coating composed of 

blend of nano acrylics and resin additives formula. MULTICERAMICSTM provides R 

equivalent "RE" insulation and great surface finish, it has no VOCs, utilizes different 

types and sizes of ceramics that block 95% 

of the sun's radiant heat visual light, ultra 

violet rays and infrared rays. 

MULTICERAMICSTM is a permanently 

flexible "breathing" membrane that stops 

water penetration, and prevents corrosion 

and surface deterioration with two 

additional advantages over other ceramic coatings. MULTICERAMICSTM has Micro 

Packing, No Fade, Nano and Cool Touch technologies. It can save thousands 

every year in utilities expenses. JUST PAINT AND SAVE! 

ACRYLIC STUCCO is a mixture of high- performance acrylics specially blended for 

breath-ability, adhesion, flexibility, texture and toughness. 

Added in the formulation is a special ceramic and aggregate 

compound to insure a stucco texture surface but with the 

added characteristics not found in standard dry mix ratios of 

stucco. It is not affected by water or moisture-penetration, 

and is designed to stay down for a long bonding life. It will 

not crack and peel. It is UV-protected for long life and 

durability against weathering whether in hot or cool climates 

or under high humidity or very dry. It is tough and durable to 

provide years of service and added beauty. 

EZ-Hot/Cold CoatingTM will stop condensation of chilled or freezing lines with just a 

1/8" of an inch, this coating is so efficient that can achieve very high insulation at less 

than half the thickness required by other insulation coatings. 

EZ-Hot/Cold CoatingTM is water borne to offer a non-flammable, no toxicity formula 

and zero VOCs for high heat or freezing applications . The Nano technology used in 

this coating offers a "micro-packing" set that is required for quick adhesion while at 

the same time offering a formulation to immediately calm the heat conduction from 

the surface of the pipe to give better adhesion to any surfaces. 

Clear-Coat is produced in two distinctive formats, a single component and a two-part 

Nano Technology "0" VOC aliphatic polyurethane enamel that forms a uniquely hard 

and durable coating film. This self-leveling coating is resistant to water, acids, solvent 

and impact. Clear-Coat is a one-coating system. Clear-Coat can be applied to metal, 

concrete, masonry, wood and many other substrates that need UV control, antimicrobial, anti-graffiti, or simply a tough clear coating to enhance and beautify any 

surface. 

RUSTVACCINETM is a one-part polyurethane coating that contains no VOC's or 

http://www.supertherm.net/home.htm[2/26/2019 5:20:22 PM] 
 

 

 

 

l_~ 11111~11\1:r - - --\~_____:___; 

• 

• 

• 

• 

• 

• 

Lu ury and Ec-0 omy Redefi ed 

WALLPANEL Corporate Home Page 

Case 3:20-cv-08190-DWL Document 1-4 Filed 07/28/20 Page 21 of 28 

That is our commitment to the industry. 

Doing the right thing for the environment, 

should not place demands, instead, it 

should offer rewards. 

WALLPANEL® can do R-30 walls roofs 

and floors with standard 6” thickness, and 

increase the R value up to R-60 on the 

same 6" thickness by coating the finished 

walls panels with our MulticeramicsTM 

insulating coating. 

We call this system SUPERTHERMAL©, 

The coating system will last a minimum of 

25 years and provide 20 minutes fire 

proofing while blocking sound by an 

additional 68%. This system can be 

assembled by a single person without effort. 

SIPs "Structural Insulated Panels" by 

definition WALLPANEL® complies with the 

description, the main difference is that 

WALLPANEL® can be shaped in the field 

without loosing it's structural strength or 

integrity, any design is possible and easily 

achieved with the wall panels, you make the 

decision right when is needed, no new 

engineering is ever needed. 

©Copyright TDE Group SUPERTHERM 

Inc. 

1999,2017 

Phones : 

888-887-0144 - 928-443-0685 

known carcinogens. Upon curing, RUSTVACCINETM provides a protective coating of 

superior adhesion, flexibility, abrasion- and impact-resistance. It is resistant to most 

chemical solvents and acid splash. RUSTVACCINETM can be used as a primer or a 

stand-alone coating. RUSTVACCINETM can be tinted to any color and can serve as a 

finished top coat as well as a primer. Can encapsulate other paints and other toxic 

materials. RUSTVACCINETM can be applied directly over cleaned flash rust or most 

firmly bonded paints. In most cases, no metal blasting is required. 

The MARBLE-EMULATION Coating is produced in two distinctive formats, a single 

component and a two-part Nano Technology "0" VOC aliphatic polyurethane enamel 

that forms a uniquely hard and durable coating film. This self-leveling coating is 

resistant to water, acids, solvent and impact. MARBLE-EMULATION is a system. 

MARBLE-EMULATION can be applied to metal, concrete, masonry, wood and many 

other substrates UV control, anti-microbial, anti-graffiti, or simply a tough clear 

coating to enhance and beautify any surface. 

The significant Difference : 

WALLPANELTM System, eliminates compliance concerns. 

Walls are very fast and easily erected with minimum personnel. 

The panels are of the standard 4" or 6" thickness. 

The studs are at the standard 16" on center spacing. 

The design makes it possible to meet the 16" on center studs and 

Trusses at 24" on center without top plates for load distribution. 

Pre-cut electrical carriers. 

Pre-molded central vacuum lines cavities that are self aligned from panel to panel. 

Pre-Molded high velocity heating air condition lines. 

No Chlorofluorocarbons, 

Consistent high R 30 - 40 - 60 values without decay. 

Meets or exceeds the requirement of all major building codes. 

The fastest build up 

Uncomplicated efficiency and highest insulation per inch of thickness 

No special engineered panels are ever needed 

Roof systems for simplicity and incredible sound and insulation comfort 

Attic less residential are incredibly easy to install 

WALLPANEL is the most economical system available 

Contact our offices for a distributor near you. 

All other inquires can be made via Email or: 

International inquires can be directed to our corporate headquarters by calling 928-776-2910 

For dealerships in the United States call our toll free 888-887-0144 

Email support@wallpanel-system.com 

http://www.supertherm.net/home.htm[2/26/2019 5:20:22 PM] 
 

 

 

 

Mult;.ceramic Coating RE19 

- -

'------.::...._, ~ 

WALLPANEL Inc. 

fl 

fl 

fl 

fl 

fl 

fl 

f1I 

fl 

The Clear Advantage 

• 

.. 

.. 

• 

• 

• 

WALLPANEL Corporate Home Page 

Case 3:20-cv-08190-DWL Document 1-4 Filed 07/28/20 Page 22 of 28 

CALL OUR OFFICES FOR INFORMATION 

ABOUT ONGOING PROJECTS NEAR YOU 

Americans are building 

energy efficient homes 

We have shipped our 

structural panels in the 

Americas from Canada to 

Uruguay 

Are some of the added benefits 

Architects, Builders and contractors 

enjoy when designing and building with 

the WALLPANELTM System. 

Any project that includes Energy 

Conservation, Green Points, Speed or 

Budgetary constrains, can be 

accomplished exceeding the highest 

expectation. WALLPANELTM 

System does not requires structural 

engineering stamps for every 

modification to the panels. 

Simplicity and Strength 

That is our commitment to the industry. 

Doing the right thing for the 

environment, should not place 

demands, instead, it should offer 

rewards. 

WALLPANEL® was designed to overcome the design shortcomings of other systems, and requires 

no special engineering or adaptation. The 18 gage studs are 16” OC, and staggered to support trusses 

at 24” OC, this eliminates the need for top plates to distribute the roof loads, since studs are at the 

standard 16” OC , sheet rock is attached in the same simple method as conventional construction. 

The studs are braced every 4' of height for outstanding load support. 

No exterior OSB sheeting is required, moisture barrier paper and lath can be attached directly to the 

panels, and stucco finished. 

Because the studs are fixed longitudinally there is no transfer of heat and the insulation, is uninterrupted 

therefore more complete, the two pounds density Polystyrene foam, is more dense than other systems 

which use a one pound density, while they need 7” of unconventional thickness to achieve R-30, 

WALLPANEL® can do R-30 with standard 6” thickness, and increase the R value up to R-60 on the 

same 6" thickness by coating the finished walls with our MulticeramicTM insulating coating. 

We call this system SUPERTHERMAL©, The coating system will last a minimum of 25 years and 

provide 20 minutes fire proofing while blocking sound by an additional 68% 

The significant Difference :

 WALLPANELTM System, eliminates compliance concerns.

 Walls are very fast and easily erected with minimum personnel.

 The panels are of the standard 4" - 6" and up to 12" of thickness.

 The studs are at the standard 16" on center spacing.

 The design makes it possible to meet the 16" on center studs and simultaneously deliver,

 Trusses support at 24" on center in the same panel without top plates for load distribution.

 Pre-cut electrical carriers.

 Pre-molded central vacuum lines cavities that are self aligned from panel to panel.

 Pre-Molded high velocity heating air condition lines.

 No Chlorofluorocarbons,

 Consistent high R 30 - 40 - 60 values without decay.

 Meets or exceeds the requirement of all major building codes. 

The fastest build up 

Uncomplicated efficiency and highest insulation per inch of thickness 

No special engineered panels are ever needed 

Roof systems for simplicity and incredible sound and insulation comfort 

Attic less residential are incredibly easy to install 

WALLPANEL is the most economical system available 

Solving global warming isn't only about installing majestic wind turbines and glistening solar 

energy systems in the desert. One of the cheapest, most effective, and safest ways to reduce global 

warming pollution is to increase our energy efficiency. In fact, by using energy efficiency 

technologies and today's know-how, we could cut our global warming pollution by a third or better. 

In the United States, we're off to a good start - innovation and improvements over the past 30 years 

have allowed our economy to grow faster than our energy consumption. Unfortunately, in the next 22 

years our electricity consumption is expected to grow by 25%. That'll mean an extra 550 million tons 

of CO2 each year that we'll have to reduce to stop global warming. 

The good news is that by aggressively improving our energy efficiency now, we can eliminate this 

increase. It'll take leadership and conscientious decisions , but there are plenty of examples of how 

energy efficiency has worked. For example, people using energy-efficient appliances in 2007 

http://www.supertherm.net/wallpanel.htm[2/26/2019 5:21:23 PM] 
Luxury and Economy Redefined 

WALLPANEL Corporate Home Page 

Case 3:20-cv-08190-DWL Document 1-4 Filed 07/28/20 Page 23 of 28 

avoided global warming pollution equivalent to nearly 27 million cars. If everyone did likewise --

and we similarly improved America's buildings, industry, and transportation -- we could reduce 

annual emissions equivalent to nearly 400 million cars. That's 2 billion fewer tons of carbon dioxide 

(more than 6,000 times the weight of the Empire State Building!). 

Building for energy-efficiency: In the United States alone, buildings are responsible for 25-35% of 

greenhouse gas emissions. By making simple changes, like using the proper insulation, we can save 

half or more of the energy it takes to heat, cool, light, and otherwise provide power to buildings. And, 

with buildings lasting for 40-50 years or more, efficiency choices we make now will last at least a 

generation. 

Contact our offices for a distributor near you. 

All other inquires can be made via Email or: 

International inquires can be directed to our corporate headquarters by calling 928-776-2910 

For dealerships in the United States call our toll free 888-WALLPNL (888-925-7265). 

Email support@wallpanel-systems.com 

©Copyright WALLPANEL Inc. 

2006,2007 

http://www.supertherm.net/wallpanel.htm[2/26/2019 5:21:23 PM] 
P! 

. WALLPA?~EL R30 • R60 

Multi-Ceramic Coating RE19 

o Fade Acrylic Stucco 

o Fad:e TM Color Retention 

Clear Coatings 

High Ternper,dure Coa.tings 

Corrosion Encapsulation 

Marble E rnul:ahon Coat 

Email Support 

Home 

~ ll!l 1 

The System for the l or cd / 

,_________~--~ 

WALLPANEL Gallery Page 

Case 3:20-cv-08190-DWL Document 1-4 Filed 07/28/20 Page 24 of 28 

Click thumbnail to enlarge. 

prev | next 

http://www.supertherm.net/gallery.htm[2/26/2019 5:21:28 PM] 
 

 

 

 

 

No Fade Acrylic Stucco 

---- - --

RustVaccine 

Case 3:20-cv-08190-DWL Document 1-4 Filed 07/28/20 Page 25 of 28 

SUPERTHERM Inc 

APPLICATION 

Clear Coating in three finishes - Hi-Gloss - Semi-Gloss - Satin Navigate: Our Site 

WOOD FINISHING 

Oil Rigs Mantainance 

ENVIRONMENT 

WOOD PRESERVATION 

ANTI-GRAFFITI 

STONE PROTECTION 

ABATING BIO-HAZARDOUS MATERIALS 

©Copyright TDE Group 

SUPERTHERM Inc. 

1999,2008 

Phones : 

888-887-0144 - 928-443-0685 

Clear-Coat is produced in two distinctive formats, a single component and a two-part 

Nano Technology "0" VOC aliphatic polyurethane enamel that forms a uniquely hard and 

durable coating film. This self-leveling coating is resistant to water, acids, solvent and 

impact. Clear-Coat is a one-coating system. Clear-Coat can be applied to metal, 

concrete, masonry, wood and many other substrates that need UV control, antimicrobial, anti-graffiti, or simply a tough clear coating to enhance and beautify any 

surface. 

SURFACE PREPARATION 

As a topcoat: Will protect longer and cost less

 Surface must be clean and free of dirt, oil, tar, grease, salts and residue.

 Surface must be completely dry before applying. 

Clear-Coat must be applied in one or multiple coats to meet any thickness 

requirement

 If applied over an existing coating and this coating is glossed, it must be sanded and

roughed before application, high gloss. Can be applied as a one-coating system for

(graffiti protection in clear finish only).

Mixing:

 Open pail, mix base with curing agent.

 Mix by hand for two minutes.

 If below 70F. degrees, allow to stand for 10 minutes.

 Begin application; During summer months, apply the coating in the morning or after

4:00 p.m.

Pot Life: 

Four hours at 70F. degrees; one hour at 90F. degrees, once base and curing agent have

been mixed. 

Support Team In Phoenix 

Product Application and Handling 

APPLICATION Cure Times: Clear-Coat can be applied by brush, roller or spray;

 If application is by brush, use a soft bristle brush. One hour to touch at 70F degrees.

 If application is by roller, use a 1/4 inch nap roller. Use a brush to remove any Over coating window is three trapped air bubbles, if any. hours at 70F. degrees or longer.

 If application is by spray, use a standard airless sprayer (2,800 psi or less) with a Fully cures in ten days. .024 tip.

NOTE: The number of coats and the thickness of each coat will be in accordance If temperature is over 90F.

with the job specifications. degrees, cure time and pot life is

Minimum Spread Rates: shortened to 1 hour. 

TEMPERATURE

Porous surfaces Apply in 2 coats at 200 sq.ft. per gallon, each coat (8 mils wet) -

(3.67 mils dry) Non-porous surfaces -- Apply at 250 sq.ft./gallon ( 6.5 mils wet) Apply between 40F. and 120F.

degrees.

 Store between 40F. and 120F. 

degrees according to hazmat

standards indicated on MSDS. 

CLEAN-UP

 During breaks, spray systems 

should be flushed with water.

 After completion, spray systems

should be flushed and cleaned with 

water.

 After completion, brushes and

rollers should be cleaned with water. 

http://www.supertherm.net/en100000.htm[2/26/2019 5:21:34 PM] 
 

Quality Without Compromise 

RustVaccine 

Case 3:20-cv-08190-DWL Document 1-4 Filed 07/28/20 Page 26 of 28 

IMPORTANT: 

Stir product thoroughly before using. Clear-Coat can be applied by brush, roller or

spray equipment. It should be applied evenly without buildup. Apply in a 2-coat

application system. CAUTION: Wear gloves and protective clothing. Wear eye

protection. WATER: Clean-up or reduction, clean equipment before breaks (lunch

hour) or at conclusion of job. 

http://www.supertherm.net/en100000.htm[2/26/2019 5:21:34 PM] 
 

 

 

 

 

 

. Multi-Ceramic Coating RE19 

--- ------

. ,, ' 

RustVaccine Home Page 

Case 3:20-cv-08190-DWL Document 1-4 Filed 07/28/20 Page 27 of 28 

SUPERTHERM Inc. 

TECH SHEET 

High Tech Corrosion - Lead - Asbestos Encapsulation Navigate Our Site 

Industrial & Residential 

PHYSICAL DATA: 

Solids: By weight 42.2% / By Volume 51.37% 

Cure time at 70F (21C): 2 hours to touch. 

Overcoat with RUSTVACCINE or other coatings 

immediately after surface is dry to the touch to achieve 

proper 

adhesion. Higher temperatures will shorten cure times, 

lower temperatures will slow curing. Can be over coated 

within1 hour after reaching the dry-to-touch stage 

Lead and Chromate free 

Cures by evaporation within 24 hours 

Weight: 12.18 lbs. per gallon 

VOC Level: "0" grams/liter 

Impact Resistance: 200+ psi front/160+ psi back 

Shelf Life: up to 2 years (unopened) under appropriate 

storage conditions see MSDS 

INSULATING WITH A SINGLE COAT NO THICKER 

THAN A BUSINESS CARD 

RUSTVACCINE penetrates and locks in to encapsulate 

rust found in and around building structures. The danger 

associated with inhaling or ingesting these particles can 

be totally eliminated. RUSTVACCINE also has the ability 

to encapsulate substrates prone to mold and mildew. 

©Copyright TDE Group SUPERTHERM Inc. 

1999,2008 

Phones : 

888-887-0144 - 928-443-0685 

DESCRIPTION: 

RUSTVACCINE is a one-part polyurethane coating that contains no VOC's or known carcinogens. 

Upon curing, RUSTVACCINE provides a protective coating of superior adhesion, flexibility, abrasionand impact-resistance. It is resistant to most chemical solvents and acid splash. 

RUSTVACCINE can be used as a primer or a stand-alone coating. RUSTVACCINE can be tinted to 

any color and can serve as a finished top coat as well as a primer. 

Can encapsulate other paints and other toxic materials. RUSTVACCINE can be applied directly over 

cleaned flash rust or most firmly bonded paints. In most cases, no near-white metal blasting is 

required. 

TYPICAL USES: 

As an encapsulant for paints, rust and other hazardous materials 

As a protective coating on metal, concrete, wood, etc. to add strength and prevent deterioration 

As a single coat for bridges, oil platforms, roofs, etc. with minimal surface preparation 

As a moisture barrier to stop water penetration, contamination, and mold/mildew 

Product Application and Handling Tinting 

APPLICATION METHODS: RUSTVACCINE can be : 

NOTE: SURFACE MUST BE COMPLETELY DRY. Tinted to any color 

Surfaces should be clean, dry and sound; all dirt, salts, oil, tar, grease and film must be removed Marine Approvals for salt 

prior to application. Can be sprayed, brushed or rolled in 2 coats (20-30 minutes apart). Before water/maritime use: 

using, stir thoroughly without creating a vortex to blend all metallic paste from the bottom. For 

specific instructions on surface preparation, mixing and application, refer to the application US Coast Guard * 

instructions for RUSTVACCINE. ABS (American Bureau of 

Shipping) * 

SAFETY PRECAUTIONS: IMO (International Marine 

Do not use this product without first taking all appropriate safety measures to Organization) * 

prevent property damage and injuries. These measures may include, without FM Factory Mutual Approval 

limitation: proper ventilation, use of proper lamps, wearing of protective clothing and E-108-00: spread of flame on 

masks, tenting, and proper separation of application areas. pitched roofs (Class "A" noncombustible) * 

IMPORTANT: Mildew Resistance - (ASTM 

Metal structures should be primed with RUSTVACCINE before applying our insulation coatings D3273, 3274) * 

Chemical Resistance (24 

hours/12 reagents) * 

Flexibility (Mandrel Bend : ASTM 

D522) - 1/8" * 

Direct Impact Resistance (ASTM 

D2794) * 

Adhesion (ASTM D3359, D4541) 

Water Vapor Transmission (ASTM 

D1653) * 

Surface Burning Characteristics 

(E84) * 

Weathering (5000 hours) - * 

Scrub Resistance (ASTM D2486) 

* 

(ASTM E1795)* 

*All these tests scheduled for 

KEEP OUT OF REACH OF CHILDREN. approval. 

For more specific safety procedures, please refer to SAFETY PRECAUTIONS: 

the RUSTVACCINE Material Safety Data Sheet. Do not use this product without first 

http://www.supertherm.net/ru_techsheet.htm[2/26/2019 5:22:35 PM] 
 

Quality Without Compromise 

RustVaccine Home Page 

Case 3:20-cv-08190-DWL Document 1-4 Filed 07/28/20 Page 28 of 28 

LIMITATION OF LIABILITY: The information contained in this data sheet is based upon tests that we 

believe to be accurate and is intended for guidance only. All recommendations or suggestions relating to 

the use of the products whether in technical documentation, or in response to a specific enquiry, or 

otherwise, are based on data which to the best of our knowledge is reliable. The products and information 

are designed for users having the requisite knowledge and industrial skills, and the end-user has the 

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

SUPERTHERM Inc. has no control over either the quality of condition of the substrate, or the many factors 

affecting the use and application of the product. 

Therefore, SUPERTHERM Inc. does not accept any liability arising from loss, injury, or damage resulting 

from such use or the contents of this data sheet (unless there are written agreements stating otherwise). 

The information contained in this data sheet is subject to modification as a result of practical experience 

and continuous development. 

taking all appropriate safety 

measures to prevent property 

damage and injuries. These 

measures may include, without 

limitation: proper ventilation, use of 

proper lamps, wearing of protective 

clothing and masks, tenting, and 

proper separation of application 

areas. 

http://www.supertherm.net/ru_techsheet.htm[2/26/2019 5:22:35 PM] 
   

Case 3:20-cv-08190-DWL Document 1-5 Filed 07/28/20 Page 1 of 3 

Exhibit D 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

TECHNICAL DATA SHEET 

Case 3:20-cv-08190-DWL Document 1-5 Filed 07/28/20 Page 2 of 3 

DESCRIPTION:

BASIC USES: 

PRODUCT

ADVANTAGES:

Percent Solids 

100% Acrylic

Weight / Gallon: 

Color: 

Drying Time:

Recommended 

Coverage:

Sizes:

MULTICERAMIC-HTM (WPMC200) 

MC502-5H-Hydrophobic Insulation RE-20

MULTICERAMICS-HTM is an interior/exterior 100 % Acrylic Waterproof 

Masonry Coating modified with Multi Ceramics Technology and Organic. 

Insulating Compounds, Made to protect residential and commercial buildings 

against the most extreme weather conditions. A high performance coating that

creates a smooth film which seals and insulates all surfaces against thermal

transfer and fire resistance. Applied as per specifications it can reduce

unnecessary re-coating and repairs. Can be tinted to light colors, or coated 

over with good quality water based paint to any color on interior applications 

MULTICERAMICS-H is the ultimate waterproof coating for all kinds of 

cementations surfaces. Our hybrid technology provides unmatched 

adhesion to concrete, drywall, stucco, brick, cinder block, metal and cpvc

pipe, galvanized ducting. It provides protection against wind driven rain

and is fire resistant to provide outstanding protection against thermal

transfer. 

* 3 in 1 Sealer-Primer-Finish * Provides a Waterproof Barrier

* Superior Adhesion * Durable- Flat Finish

 * Dirt pick-up resistance * Stain Resistant

* Bio-ProofTechnology * Energy Savings

* Fire resistance * Water Clean Up 

TECHNICALDATA

59.89 ± 1% by weight Finish: Flat

45.92 ± 1% by volume

11.6 ± 0.5 lbs. Viscosity: 90-100 Ku's

White (or tint light colors) PercentPigment

By weight: 38.7 ± 1% 

To touch: 1 hr To 

recoat: 24 hrs Flash Point: Non-flammable

Fully cure: 7 days

Theoretical 1000 sq./ft. per 

100 sq./ft. @ 10 dry mils, Coverage: gallon @ 1 mils 

13 wet mils VOC’s: 0 

5 gallons 

1 gallon 

Do not thin. Use only as it comes.
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

--------

Case 3:20-cv-08190-DWL Document 1-5 Filed 07/28/20 Page 3 of 3 

SINGLE COAT: APPLY AT 13 MILS WET/ DRY AT 10 MILS.

SYSTEM SPECIFICATIONS FOR TWO COATS SYSTEM

Apply 1st Coat at a rate of 1 gallon per 75-100 sq.ft.

8 mils dry / 10 mils wet

Apply 2nd Coat at a rate of 1 gallon per 100-125 sq.ft. 8 mils dry /

10 mils wet

NOTE: This product has excellent suspension and requires minimal

stirring. Do Not Thin.

SURFACE PREPARATION 

Remove all dirt, dust loose or flaking rust. Use mild bleach solution

with water to remove any mildew, algae, or mold from surface. 

Surface must be power washed to remove dirt, loose paint, excess 

rust, and other foreign matter which could prevent proper adhesion.

Surface must be completely dried before applying coating.

Remove efflorescence (white powdery, crystal-like deposit visible on

masonry surfaces), using a solution of 1 quart of muriatic acid and 3

quarts of water. Use long handled brush. Rinse completely.

Caution: Read warnings on label. Wear rubber gloves and safety

glasses. Never mix acid with other substances. Only mix with water.

CRACKS

Above grade or architectural walls: Make sure cracks and holes are

clean and dry, with a putty knife apply EZ SEAL-Crack Filler into

crack and 2 inches to both sides. Let dry thoroughly 24 hours before

Coating. Refer to TDS. 

Below grade or retaining walls: Make sure cracks and holes are

clean; dry and free of loose particles. Patch all holes and cracks using

a good quality, fast setting hydraulic cement, and smooth the patch

evenly with the surface around it. Floor joints where walls and floor 

meet must be checked, for possible breaks, if necessary fill with a

good quality fast setting hydraulic cement. 

APPLICATION LIMITATIONS

Do not apply below 50° F (10°C) or when rain is forecasted. Low

temperatures and high humidity will prolong coat dry time. Allow 4

+/- hours for coating to dry prior to being subjected to rain. KEEP

FROM FREEZING.

CLEAN UP

Clean brushes and tools immediately after use with warm soapy

water. Completely flush all spray equipment with this solution.

SAFETY INFORMATION

Refer to product Material Safety Data Sheet (MSDS) prior to product

use.

IMPORTANT: Even though MULTICERAMICS-HTM will resist

standing water (for 50 hours), do not use on roofs with a slope less 

than 1⁄2 inch per foot. (If used on roof with slope less than 1⁄2 inch per 

foot, warranty will be void if not re-coated annually with one coat of

MULTICERAMICS-HTM). 

Mildewed Surface: Any existing mildew on the surface must be

completely killed and removed prior to application of the product. 

(Any mildew not removed may continue to grow through the new

finish). Scrub mildewed surface with the mixture of 1 quart of 

household bleach with 3 quarts of warm water, rinse completely and

let dry.

Repair cracks and seams: Make sure cracks, seams, and flashings

are clean and dry. With a putty knife, apply Crack Filler and a

polyester weave over cracks, seams, flashings and around any

standing objects about 2 inches to both sides, and let dry thoroughly

for 24 hours before applying MULTICERAMICS-HTM. 

Application by roller: Apply the first coat of MULTICERAMICSHTM onto the roof a rate of 1 gals. 100 sq. ft. Avoid going twice

over the same area. (Be sure to follow drying time between coats or 

membrane will be lifted or broken.) Allow 24 hours between coats 

as needed. Apply second coat in same manner as first (spreading it

with roller). Second coat should be at a rate of one gallon per 80 sq. 

ft. Let dry 24 hours between coats.

Water ponding areas: Areas where ponding water lasts one day or 

more must be repaired using roof drains or other corrective measures

before applying MULTICERAMICS-HTM

Concrete Roofs: Repair holes or any weakened areas of concrete

surface with good quality masonry cement. Paint area to be repaired

with a bonding Agent and let dry. Add one gallon of bonding agent

to each fifty pounds of cement in the mix. Apply concrete mix and let

cure for one week. Repair cracks using Crack FillerTM the patching 

weave as recommended.

Apply one coat of MULTICERAMICS-HTM. Let dry 24 hours and 

apply a second coat when required.

Metal Roofs: Remove rust and prime non-galvanized metals with

Metal Master Primer. For galvanized metals, use

MULTICERAMICS-HTM Fasteners must be covered with Crack

FillerTM, and let dry 24 hours. Apply MULTICERAMICS-HTM Let

dry 24 hours and apply a second coat.

Polyurethane Foam: Make sure surface is in good conditions, free

of holes and cracks. If it’s in optimum conditions apply one coat of 

MULTICERAMICS-HTM, let dry for 24 hours and apply a second

coat. 

Fiber Glass, Plastics,Pvc: Clean surfaces free of grime and dust

apply MULTICERAMICS-HTM at 13 mils wet/10 mils dry. 

Built Up Roofs: Remove all loose gravel and clean roof thoroughly. 

Repair cracks with Crack FillerTM and MULTICERAMICS-HTM,

sealing completely all of the gravel. Let dry 24 hours. Continue

with two coats of MULTICERAMICS-HTM, allowing 24 hours to dry

between coats.

Asphalt Singles: Roof must be clean and completely dry. Apply 2

coats of MULTICERAMICS-HTM at a rate of 100 sq. ft. per gallon. 

Let dry 24 hours between coats. Be sure all tabs are completely

sealed. If not, apply Elastomeric Crack FillerTM and

MULTICERAMICS-HTM High Strength Polyester Weave on tab

joint as recommended, followed by an addition coat of 

MULTICERAMICS-HTM. 

Application: Apply MULTICERAMICS-HTM with a 1⁄4" Rough

Surface Roller or airless spray. Wait 24 hours between coats. Apply

only when temperature is above 50°F (10°C). Do not apply if

temperature is expected to drop below 50°F ( 10°C) before the

coating has completely dried. If roof is hot, spray with water to

avoid sealer from drying too fast. Two full coats are generally needed 

for proper sealing. Always apply coats in different directions. Never 

thin or dilute from full strength.

Recommended Equipment: Use an airless pump with pressure of 

1,500 to 2,000 psi. A fluid delivery of 1 to 2 gallons per minute with 

a spray tip of .026 to .035 will be adequate. Wait 24 hours between

coats. The hoses should be at least 3/8” inside diameter and of the

high-pressure rate type. If the hose length is more than fifty feet, a

larger inside diameter will be required. 

Drying Time: Approximately 60 minutes to touch. Cure time is 7

days controlled by thickness of the applied coating, relative humidity

and temperature. Allow 24 hours between coats.

Weather: Select a warm, clear and sunny day. Consult your weather

bureau to make sure there is no forecast of rain. Do not apply after

4:00pm. Keep rain-free for a minimum of 6 hours after application.

Notice: The technical data contained herein are true and accurate to

the best of our knowledge. Published technical data and instructions 

are subject to change without prior notice.
   

Case 3:20-cv-08190-DWL Document 1-6 Filed 07/28/20 Page 1 of 3 

Exhibit E 
DESCRIPTION: 

BASIC USES: 

PRODUCT 

ADVANTAGES: 

TECHNICAL DATA SHEET 

MULTICERAMICS-U-XtraTM 

MC-502-4X 

MULTICERAMICS-UTM is a thick, one component high performing, 

Urethane Ceramic Rubberized Elastomeric roof and wall sealer. It will 

provide a 100% waterproof and weather proof seal adhering tightly to any 

surface without the aid of a primer. The ceramic composition will 

significantly lower the interior temperature by reflecting 73% of all the 

sunrays and by eliminating 95% of the heat received.) 

For waterproofing and protecting a wide assortment of roofing substrates 

that are structurally sound such as conventional bituminous built-up roofs, 

polyurethane foam, concrete, metal, aged galvanize, bonded tar and gravel 

and or asphalt shingles adding fire resistance when applied in two coats. 

* Dries ultra fast 

* High resistance to algae 

* Dirt pick-up resistance 

* Water ponding resistant 

* 100% UV rays resistant 

TECHNICAL DATA 

* Seals cracks and stops leaks 

* Ultra white, thick and seamless 

* Provides insulation, thus avoiding 

the heat from entering the building 

* Intumesces when exposed to heat 

source protecting substrate damage 

Percent Solids: 59.89 ± 1 % by weight 

45.92 ± 1 % by volume 

Finish: Flat (5°-10°)* 

*Geometry 60° 

Weight/ Gallon: 11.33 ± 0.5 lbs. 

Color: 

Drying Time: 

Recommended 

Coverage: 

Sizes: 

Thinning: 

Blue on application; 

White in 3-4 hours 

To touch: 1 hr 

To recoat: 24 hrs 

60 sq ./ft. @ 15 dry mils, 

33 wet mils 

5 gallons 

1 gallon 

Do not thin. Use only as it comes. 

Viscosity: 120-125 Ku's 

Percent Pigment 

by Weight: 38.7 ± 1 % 

Flash Point: Non-flammable 

Theoretical Up to 650 sq./ft. 

Coverage: per gallon @ 1 mil 

Section 11-10 

Case 3:20-cv-08190-DWL Document 1-6 Filed 07/28/20 Page 2 of 3 
Surface Protection: Make certain the roof substrate is 

thoroughly clean. Remove all foreign matter and old 

loose coatings by sandblasting, high-pressure water 

blasting (not recommended on shingles) or wire 

brushing. Kill and remove all mildew or fungus 

growth on the substrate, flush with water and let dry 

completely. Substrate must be dry at time of applying 

primer and subsequent coating. Be sure roof is well 

ventilated, in order to avoid condensation on the roof. 

Do not use on rubber roofs. Roof with standing water 

and improperly drained areas require annual 

maintenance (two coats ofMULTICERAMICS-UTM 

every year. 

IMPORTANT: Even though MULTICERAMICSUTM will resist standing water (for 50 hours), do not 

use on roofs with a slope less than 1⁄2 inch per foot. (If 

used on roof with slope less than 1⁄2 inch per foot, 

warranty will be void if not re-coated annually with 

one coat ofMULTICERAMICS-UTM). 

Mildewed Surface: Any existing mildew on the 

surface must be completely killed and removed prior 

to application of the product. (Any mildew not 

removed may continue to grow through the new 

finish). Scrub mildewed surface with the mixture of I 

quart of household bleach with 3 quarts ofwann 

water, rinse completely and let dry. 

Repair cracks and seams: Make sure cracks, seams, 

and flashings are clean and dry. With a putty knife, 

apply Crack Filler and a polyester weave over cracks, 

seams, flashings and around any standing objects 

about 2 inches to both sides, and let dry thoroughly for 

24 hours before applying MULTICERAMICS-UTM. 

Application: Apply the first coat by pouring container 

of MULTICERAMICS-UTM onto the roof and 

spreading at a rate of2-4 gals. 120-240 sq. ft. Avoid 

going twice over the same area. (Be sure to follow 

drying time between coats or membrane will be lifted 

or broken.) Allow 24 hours between coats as needed. 

Apply second coat in same manner as first (by pouring 

product and spreading it with roller). Second coat 

should be at a rate of one gallon per 80 sq. ft. Let dry 

24 hours between coats. 

Water ponding areas: Areas where ponding water 

lasts one day or more must be repaired using roof 

drains or other corrective measures before applying 

MULTICERAMICS-UTM 

Concrete Roofs: Repair holes or any weakened areas 

of concrete surface with good quality masonry cement. 

Paint area to be repaired with a bonding Agent and let 

dry. Add one gallon of bonding agent to each fifty 

pounds of cement in the mix. Apply concrete mix and 

let cure for one week. Repair cracks using Crack 

FillerTM the patching weave as recommended 

Apply one coat ofMULTICERAMICS-UTM. Let dry 

24 hours and apply a second coat. 

Metal Roofs: Remove rust and prime non-galvanized 

metals with Metal Master Primer. For galvanized 

metals, use MULTICERAMICS-UTM Fasteners must 

be covered with Crack FillerTM, and let dry 24 hours. 

Apply MUL TICERAMICS-UTM Let dry 24 hours and 

apply a second coat. 

Polyurethane Foam: Make sure surface is in good 

conditions, free of holes and cracks. !fit's in optimum 

conditions apply one coat ofMULTICERAMICS-0TM, 

let dry for 24 hours and apply a second coat. 

Built Up Roofs: Remove all loose gravel and clean 

roof thoroughly. Repair cracks with Crack FillerTM 

and MULTICERAMICS-UTM, sealing completely all 

of the gravel. Let dry 24 hours. Continue with two 

coats ofMULTICERAMICS-UTM, allowing 24 hours 

to dry between coats. 

Asphalt Singles: Roof must be clean and completely 

dry. Apply 2 coats of MUL TICERAMICS-UTM at a 

rate of 60 sq. ft. per gallon. Let dry 24 hours between 

coats. Be sure all tabs are completely sealed. If not, 

apply Elastomeric Crack FillerTM and 

MUL TICERAMICS-UTM High Strength Polyester 

Weave on tab joint as recommended, followed by an 

addition coat ofMULTICERAMICS-UTM. 

Application: Apply MULTICERAMICS-UTM with a 

1⁄4" Rough Surface Roller or airless spray. Wait 24 

hours between coats. Apply only when temperature is 

above 50°F (10°C). Do not apply if temperature is 

expected to drop below 50°F ( 10°C) before the 

coating has completely dried. If roof is hot, spray with 

water to avoid sealer from drying too fast. Two full 

coats are generally needed for proper sealing. Always 

apply coats in different directions. Never thin or 

dilute from full strength. 

Recommended Equipment: Use an airless pump 

with pressure of 1,500 to 2,000 psi. A fluid delivery 

of I to 2 gallons per minute with a spray tip of .026 to 

.035 will be adequate. Wait 24 hours between coats. 

The hoses should be at least 3/8" inside diameter and 

of the high-pressure rate type. If the hose length is 

more than fifty feet, a larger inside diameter will be 

required. 

Cleanup: Clean roller and equipment after use with 

wann soapy water. 

Drying Time: Approximately 60 minutes to touch. 

Cure time is controlled by thickness of the applied 

coating, relative humidity and temperature. Allow 24 

hours between coats. 

Weather: Select a warm, clear and sunny day. 

Consult your weather bureau to make sure there is no 

forecast of rain. Do not apply after 4:00pm. Keep 

rain-free for a minimum of6 hours after application. 

Notice: The technical data contained herein are true 

and accurate to the best of our knowledge. Published 

technical data and instructions are subject to change 

without prior notice. 

M.S.D.S: Available upon request. 

Case 3:20-cv-08190-DWL Document 1-6 Filed 07/28/20 Page 3 of 3 
   

Case 3:20-cv-08190-DWL Document 1-7 Filed 07/28/20 Page 1 of 3 

Exhibit F 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Case 3:20-cv-08190-DWL Document 1-7 Filed 07/28/20 Page 2 of 3 

- MULTIC RAMICS-H 

PRODUC USE: INSULA ION DA ED: 04/23/2014 PRODUC I.D. MC502-5H 

EMERGENCY ELEPHONE NUMBER: 888-887-0144 

SEC ION II - HAZARDOUS 

INGREDIEN S: 

HAZARDOUS INGREDIEN S % CAS/PIN LD50 (Species/Route) LC50 (Species) 

None Known 0 N/A N/A N/A 

VOC (gm of VOC less water) SEC ION III - PHYSICAL S A E: 0 gm/L 

PHYSICAL S A E: White 

APPEARANCE AND ODOR: Missible in water 

SOLUBILI Y IN WA ER: Soluble/miscible 

FREEZING POIN : BOILING POIN : 100 c pH: 

SPECIFIC GRAVI Y: ODOR HRESHOLD: Mild 

COEFF. WA ER/OIL: EVAPORA ION RA E: (BUOAC =1) 1 for water % VOLA ILES: N/A 

VAPOR DENSI Y (Air=1): 1 VAPOR PRESSURE: WEIGH /gal = 11 ± LBS 

SEC ION IV - FIRE OR EXPLOSION HAZARD: 

CONDI IONS OF FLAMMABILI Y: Not flammable, water-based product 

Oxides of carbon. If water is all evaporated non-volatiles will burn 

HAZARDOUS COMBUS ION PRODUC S: giving off Carbon monoxide, Carbon dioxide, and hydrogen 

chloride. 

AU O IGNI ION EMP: NAP MINIMUM IGNI ION ENERGY: NAV 

FLAMMABLE LIMI S: (Lower) LEL Not Applicable (Upper) NAP 

FIRE POIN : NAV FLASH POIN & ME HOD: NAP 

SENSI IVI Y O S A IC SENSI IVI Y O MECHANICAL IMPAC ?: No No DISCHARGE? 

Special Firefighting Procedures: None except in confined areas. Wear NOSH/MSHA approved 

SPECIAL PROCEDURES: self-contained full face positive pressure breathing apparatus and appropriate protective 

clothing. 

Water is recommended for combustible fiber containers of 50 gallons. his is a water-bone 

MEANS OF EX INC ION: coating; it will not burn, unless all the water has evaporated. he dried polymer in the 

product will burn. In this case, use foam, carbon dioxide, dry chemical or water. 

SEC ION V - REAC IVI Y DA A: Stable 

CHEMICAL INCOMPA IBILI Y: Acid and salt solutions may coagulate the binder. Avoid strong oxidizing substances. 

CONDI IONS OF INS ABILI Y: Avoid extreme heat. Avoid freezing, product will coagulate. 

Oxide of carbon and hydrogen chloride may be formed by the HAZARDOUS DECOMPOSI ION PRODUC S: pyrollysis of solids. 

CORROSIVE BEHAVIOR? No 

SEC ION VI - OXICOLOGICAL PROPER IES: 

ROU ES OF EN RY: 

SKIN CON AC No SKIN ABSORP ION No EYE CON AC Yes 

SYNERGIS IC INHALA ION No INGES ION Yes None known PRODUC S 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

I 

I 

Case 3:20-cv-08190-DWL Document 1-7 Filed 07/28/20 Page 3 of 3 

- MULTIC RAMICS-H 

EXPOSURE LIMI S: 

EFFEC S OF ACU E EXPOSURE: 

EFFEC S OF CHRONIC EXPOSURE: 

ENGINEERING CON ROLS: 

S ORAGE REQUIREMEN S: 

HANDLING 

PROCEDURES/EQUIPMEN : 

LEAK/SPILL PROCEDURES 

WAS E DISPOSAL: 

SENSI IZA ION: 

SEC ION VIII -: FIRS AID 

INHALA ION Respiratory Protection 

EYES: 

SKIN: 

O HER: 

SEC ION IX -: LABELING 

REGULA ORY INFORMA ION 

SEC ION VIII - FIRS AID 

MEASURES: 

MSEC ION X -: USER’S 

RESPONSIBILI Y 

OSHA Permissible Exposure Limits (PEL) and hreshold Limit Value (ACGIH)- Not established. 

Liquid splash could result in eye or nose irritation and /or headache. 

Excessive exposure to liquid product may result in minor irritations. 

Protect product from overheating. Avoid freezing temperatures. Storage tanks should be lined 

or constructed of 316 SS to prevent corrosion. 

Other precautions: For Industrial use only. No special precautions needed if product is handled 

in accordance with good manufacturing practices. Avoid freezing, since this will cause the 

binder to coagulate. Always wash up after handling product and before eating, drinking, 

smoking, or using restroom facilities. 

Restrict areas to only those personnel needed. Stop discharge and contain spill or contaminated 

material using, dike, barrier or other means. Recover with pumping equipment, vacuum truck, 

absorbent, vermiculite or other means. Place contaminated material in suitable containers for 

further handling. Check federal, state and local reporting regulations. Do not flush to stream, 

other bodies of water or sewer. Avoid contact with eyes or skin. 

a) Recycle, if feasible. b) Incinerate in authorized facility. C) treatment at industrial or liquid 

waste facility. d) Landfill in authorized facility. (Solidification or fixation may be required prior 

to landfill disposal) Notes: If discarding this material, dispose of in accordance with local, state, 

and federal regulations. 

Not expected 

None should be required if adequate ventilation is provided. Otherwise, a NIOSH/MSHA 

approved chemical cartridge respirator with organic vapor cartridge) is recommended within 

equipment limitations. Comply with OSHA 1910.134 (29 CRF), Respiratory Protection. 

Safety glasses and available eye bath. 

For hands and body: Chemical resistant gloves impervious to water and soap are recommended 

for hand protection. Work clothing for general body protection and other protective clothing as 

necessary to prevent repeated or prolonged skin contact. 

Ventilation: General (mechanical) room ventilation is expected to be satisfactory. Other: 1) Use 

under well-ventilated conditions. 2) For personal hygiene protection, we recommend that the 

employees wash thoroughly after handling product. Always wash up before eating, dinking, 

smoking or using restroom facilities. 

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

 OSCA he product meets the compositional requirements of the toxic substance control act 

and contains only chemicals ingredients that are listed on tosca inventory. Sara title III, sec 

313, this product does not contain toxic chemical at or above the minimum concentrations 

subject to the reporting requirements of section 313 of title III of the Superfund Amendments 

and reauthorization Act of 1986 (SARA) and 40 C.F.R. part 372. PROP 65. Are paints and 

coatings containing ingredients that are allowed for use in the state of California under the 

regulations of prop 65 which contain no known chemicals to cause cancer and/or birth defects 

or other reproductive harm D.O. . shipping name: Non-Regulated D.O. . shipping label: Not 

Applicable 

A bulletin like this cannot be expected to cover all possible individual situations. As the user has 

the responsibility to provide a safe workplace, all aspects of an individual operations should be 

examined to determine if or where precautions, in additions to those described herein, are 

required. Any health hazard and safety information contained herein should be passed on to 

your consumers and/or employees, as the case may be. Wallpanel, Inc. must rely on the user 

to utilize the information we have supplied to develop work practice guidelines and employee 

instructional programs for the individual operation. 

DISCLAIMER OF LIABILI Y: he information contained herein is to the best of our knowledge and belief, accurate.