Case: 3:22-cv-01389 Doc #: 1 Filed: 08/05/22 1 of 23. PageID #: 1 

UNITED STATES DISTRICT COURT 

IN THE NORTHERN DISTRICT OF OHIO 

WESTERN DIVISION 

UNITED STATES OF AMERICA, 

Plaintiff, 

v. 

AXIS LED GROUP, LLC, a limited liability 

company; 

Case No. 

COMPLAINT FOR PERMANENT 

INJUNCTION, CIVIL 

PENALTIES, AND OTHER 

RELIEF 

ALG-HEALTH LLC, a limited liability company; 

and 

ADAM J. HARMON, individually and as an 

officer of AXIS LED GROUP, LLC and 

ALG-HEALTH LLC, 

Defendants. 

Plaintiff, the United States of America, acting upon notification and authorization to the 

Attorney General by the Federal Trade Commission (“FTC” or “Commission”), pursuant to 

Section 16(a)(1) of the FTC Act, 15 U.S.C. § 56(a)(1), for its Complaint alleges: 

1. Plaintiff brings this action under Sections 5(m)(1)(A), 13(b), and 19 of the Federal 

Trade Commission Act (“FTC Act”), 15 U.S.C. §§ 45(m)(1)(A), 53(b), and 57b; the COVID-19 

Consumer Protection Act of the 2021 Consolidated Appropriations Act (the “COVID-19 Act”), 

Pub. L. No. 116-260, 134 Stat. 1182, Title XIV, § 1401(b)(1); and Section 323.4 of the Made in 

USA Labeling Rule (the “MUSA Labeling Rule”), 16 C.F.R. § 323.4, which together authorize 

the Plaintiff to seek, and the Court to order, permanent injunctive relief, monetary relief, civil 

penalties, and other relief for the numerous acts and practices of Defendants Axis LED Group, 

LLC, ALG-Health LLC, and Adam J. Harmon in violation of Sections 5(a) and 12 of the FTC 

Act, 15 U.S.C. §§ 45(a), 52 and in violation of the Made in USA Labeling Rule, 16 C.F.R. Part 

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323, described herein. These deceptive acts or practices include but are not limited to: (1) the 

labeling and advertising of certain products containing significant imported content as “Made in 

USA;” and (2) the making of other false or misleading claims relating to Defendants’ personal 

protective equipment products and the prevention or mitigation of COVID-19. 

Jurisdiction and Venue 

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

1345, and 1355. 

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

1395(a), and 15 U.S.C. § 53(b). 

Plaintiff 

4. This action is brought by the United States of America on behalf of the FTC. The 

FTC is an independent agency of the United States Government given statutory authority and 

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

U.S.C. §§ 45(a), which prohibits unfair or deceptive acts or practices in or affecting commerce, 

and Section 12 of the FTC Act, 15 U.S.C. § 52, which prohibits false advertisements for food, 

drugs, devices, services, or cosmetics in or affecting commerce. The FTC also enforces the 

COVID-19 Act, which provides for civil penalties for any person who engages in a deceptive act 

or practice in or affecting commerce associated with the treatment, cure, prevention, mitigation, 

or diagnosis of COVID-19 for the duration of the COVID-19 public health emergency. Pub. L. 

No. 116-260, Title XIV, § 1401(b)(1). The FTC also enforces the MUSA Labeling Rule, which 

prohibits labeling any product with an unqualified “Made in USA” or equivalent claim unless 

the final assembly or processing of the product occurs in the United States, all significant 

processing that goes into the product occurs in the United States, and all or virtually all 

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ingredients or components of the product are made and sourced in the United States. 16 C.F.R. § 

323.2. 

Defendants 

5. Defendant Axis LED Group, LLC (“Axis”) is an Ohio limited liability company 

with its principal place of business at 520 West Mulberry Street, Bryan, Ohio 43506. Axis 

transacts or has transacted business in this District and throughout the United States. At all times 

relevant to this Complaint, acting alone or in concert with others, Axis has advertised, marketed, 

distributed, or sold light-emitting diode (“LED”) or personal protective equipment (“PPE”) 

products to consumers throughout the United States. 

6. Defendant ALG-Health LLC (“ALG-Health”) is an Ohio limited liability 

company with its principal place of business at 520 West Mulberry Street, Bryan, Ohio 43506. 

ALG-Health transacts or has transacted business in this District and throughout the United 

States. At all times relevant to this Complaint, acting alone or in concert with others, ALGHealth has advertised, marketed, distributed, or sold LED or PPE products to consumers 

throughout the United States. 

7. Defendant Adam J. Harmon (“Harmon”) is the President and Chief Executive 

Officer of both Axis and ALG-Health. At all times relevant 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 Axis and ALG-Health, including the acts and practices 

set forth in this Complaint. Defendant Harmon resided in this District at the time of the matters 

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

this District and throughout the United States. 

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Common Enterprise 

8. Defendants Axis and ALG-Health (collectively, “ALG” or “Corporate 

Defendants”) have operated as a common enterprise while engaging in the deceptive acts and 

practices and other violations of law alleged below. Corporate Defendants have conducted the 

business practices described below through interrelated companies that have common ownership, 

officers, managers, business functions, employees, and office locations, and that commingled 

funds. 

9. Specifically, at all times relevant to this Complaint, the Corporate Defendants 

operated under Defendant Harmon’s unified control. Defendant Harmon directed the Corporate 

Defendants’ business and marketing activities interchangeably through his Axis and ALG-Health 

email addresses, ordered and received ALG-Health shipments under the Axis name, commingled 

corporate funds, and housed corporate activities in the same physical space. 

10. Because these Corporate Defendants have operated as a common enterprise, each 

of them is liable for the acts and practices alleged below. 

Commerce 

11. At all times relevant 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 Activities 

12. Defendant Harmon formed Axis in Ohio in 2015. Exhibit A. 

13. Defendant Harmon filed articles of incorporation for ALG-Health in Ohio in June 

2020. Exhibit B. 

14. As described in Paragraph 9, at all times material to this Complaint, Defendant 

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Harmon served as an officer of the Corporate Defendants, which he operated as a unified entity. 

15. Defendant Harmon holds sole responsibility for, and has directed publication 

of, all ALG marketing claims. 

Defendants have falsely marketed, labeled, and sold wholly imported 

Chinese lighting products, or products containing significant Chinese inputs, as 

Made in the United States. 

16. Since 2015, ALG has marketed and sold LED lights, tubes, and fixtures to 

consumers and the United States government. 

17. In 2016, the Commission received reports that ALG falsely advertised a line of 

imported LED bulbs called “Patriot Tubes” as Made in the United States (“MUSA”). 

18. Specifically, ALG blanketed its website and social media with unqualified U.S.-

origin claims for these products, stating the Company’s “advances in manufacturing processes 

and efficiency have finally allowed us to produce USA-made products at competitive prices.” 

Exhibit C. 

19. During the FTC’s investigation of these reports, Defendant Harmon admitted 

Patriot Tubes included significant Chinese components. However, Defendant Harmon claimed 

Patriot Tubes were assembled in the United States. 

20. Defendant Harmon asserted Patriot Tubes qualified as “domestic end products” 

under the Buy American Act, 41 U.S.C. §§ 8301-8305 (“BAA”),1 and produced a letter 

purportedly confirming this fact. Exhibit D. 

21. During the 2016 investigation, Defendant Harmon reviewed and acknowledged 

1 BAA establishes preferences for domestic end products and construction materials in government acquisitions, and 

defines those terms as they are used in that limited context. See 48 CFR § 25.003 (stating that for purposes of BAA, 

“domestic end product[s]” and “domestic construction material[s]” include, among other things, certain manufactured 

products or materials where either the cost of the components mined, produced, or manufactured in the United States 

exceeds 50% of the cost of all components, or the product or material is a commercially available off-the-shelf item). 

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FTC guidance and caselaw providing that marketers should not claim products are MUSA unless 

they can substantiate such products are “all or virtually all” MUSA. Defendant Harmon agreed 

to market his products consistent with FTC guidance and caselaw going forward. 

22. On January 18, 2017, FTC staff issued a letter on the public record explaining the 

investigation into ALG was closed based on Defendant Harmon’s: (1) production of a certificate 

stating his products qualified as “Domestic End Products” under the BAA; (2) commitment to 

remove all unqualified MUSA claims from his website; and (3) agreement to qualify “Buy 

American Act Compliant” claims on any marketing materials not specifically targeted at 

government purchasers. The letter reiterated guidance and caselaw previously discussed with 

Defendant Harmon providing that marketers should not make unqualified MUSA claims unless 

the products advertised are “all or virtually all” MUSA. Exhibit E. 

23. Since 2017, in numerous instances, Defendants have continued to market Patriot 

LED products to consumers and the U.S. government as “Assembled in the USA” and “Buy 

American Act Compliant” including, but not limited to, through the following statements and 

depictions: 

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Exhibit F, Axis LED Catalogue. 

24. In truth and in fact, in numerous instances, ALG wholly imports these products 

from China. 

25. In numerous instances, ALG employees have peeled “Made in China” stickers off 

LED products in ALG facilities and replaced them with MUSA labels. Exhibit G, Morlock Decl. 

at ¶¶ 5-8; see also Exhibit H, Hutson Decl. at ¶ 5 (stating the lighting operation consisted of 

simply re-boxing Chinese lighting products). 

26. Since 2015, ALG has supplied hundreds of thousands of lights to consumers and 

the U.S. government that underwent no manufacturing in the United States, other than occasional 

quality checks. Exhibit G, Morlock Decl. at ¶ 9. 

During the COVID-19 pandemic, Defendants falsely marketed, labeled, and sold wholly or 

partially imported Chinese PPE as MUSA, and made other deceptive claims for PPE. 

27. On January 31, 2020, Health and Human Services Secretary Alex M. Azar II, 

pursuant to his authority under Section 319 of the Public Health Service Act, declared a public 

health emergency, which remained in effect throughout the activities detailed below, and 

beyond. On March 11, 2020, the World Health Organization declared the 2019 novel 

coronavirus (“COVID-19”) outbreak a global pandemic.2 

2 See WHO Director-General’s Remarks (March 11, 2020), available at 

https://www.who.int/director-general/speeches/detail/who-director-general-s-opening-remarksat-the-media-briefing-on-covid-19 -- 11-march-2020, 

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28. In early 2020, seeking to capitalize on demand because of the COVID-19 

pandemic, ALG began selling PPE, including KN95 respirators,3 gloves, and gowns, out of 

ALG’s facility in Defiance, Ohio. 

29. In March 2020, Defendants began operating as ALG-Health. 

30. ALG-Health primarily markets and sells PPE products online, through its own 

website, alg-health.com, and through www.stockmedicalsuppply.com. 

31. In late 2020, based on documentation supplied by ALG-Health, the National 

Institute for Occupational Safety & Health (“NIOSH”)4 certified certain of Defendants’ masks as 

N95 respirators. 

32. Starting in 2020, Defendants disseminated or caused to be disseminated, 

advertisements, packaging, and promotional materials for PPE products, including, but not 

necessarily limited to, the attached Exhibits I-M: 

3 A respirator labeled as a KN95 respirator is expected to conform to China’s GB2626 standard. 

4 The Occupational Safety and Health Act of 1970, codified at 29 U.S.C. §§ 651-678, established 

NIOSH as a research agency focused on the study of worker safety and health, and empowering 

employers and workers to create safe and healthy workplaces. NIOSH is part of the U.S. Centers 

for Disease Control and Prevention, in the U.S. Department of Health and Human Services. See 

https://www.cdc.gov/niosh/about/default.html. Among other things, NIOSH approves N95 

respirators using standards promulgated under 42 C.F.R. § 84. NIOSH does not approve KN95 

products, or any other respiratory protective devices certified to international standards. 

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a. “Manufactured in USA” 

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Exhibit I, Composite Exhibit, ALG Health website and social media posts. 

b. “Made in USA” 

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Exhibit J, Composite Exhibit, ALG Social Media Posts. 

c. “ALG Health is producing N95 respirators and disposable masks that are 

100% Made in the USA for our men and women first responders, medical 

personnel, military, government agency, and humanitarian efforts.” 

Exhibit K, ALG YouTube Video. 

d. 

AN AMERICAN SOLUTION 

Our manufacturing facility was built in NW Ohio and is completely staffed by American 

workers, making ALG Health one of the very few PPE facilities in America that is 100% Made 

in the USA. We are fully Berry Amendment (10 U.S.C 2533a) compliant and adhere to the laws 

passed by the United States Congress. 

Exhibit L, alg-health.com (webarchive.org capture from Dec. 28, 2020). 

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e. Healthcare customers should “purchase American-made PPE and masks 

so that our heroic frontline workers do not have their safety put at risk by 

relying on foreign-made products”; and “imported products are not tested 

and could be unsafe.” Exhibit M, Composite Exhibit, ALG Social Media 

Posts. 

33. In numerous instances, including but not limited to the promotional materials 

referenced in Paragraph 32, Defendants have represented, expressly or by implication, that their 

PPE products are all or virtually all made in the United States. 

34. In numerous instances, including but not limited to the promotional materials 

referenced in Paragraph 32, Defendants have represented, expressly or by implication, that 

because they are all or virtually all made in the United States, Defendants’ products are safer or 

provide superior protection from COVID-19. 

35. In fact, in numerous instances, the products advertised using the statements 

described in Paragraph 32 were wholly imported from China. See Exhibit G, Morlock Decl. at 

¶¶ 24, 33 (“Probably 90% of the masks Mr. Harmon sold were brought in from China as finished 

masks. Maybe more.”); Exhibit H, Hutson Decl. at ¶¶ 7, 14 (“If I had to guess I would estimate 

there was a 90%-10% split between the ALG masks that were wholly imported and those that 

were ‘made’ in Ohio.”); Exhibit N, Feeney Decl. at ¶ 28 (“If I had to guess, I would say probably 

80% or so of the masks we sold were imported masks.”). 

36. Indeed, in numerous instances, Defendants received Chinese KN95s, unpacked 

the completed respirators, stripped off Chinese origin labels, printed ALG and NIOSH labels on 

the respirators, and then re-boxed the respirators in ALG packaging with MUSA labels. Exhibit 

G, Morlock Decl. at ¶ 24 (“[H]undreds of thousands of Chinese masks were arriving from Venas. 

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As each shipment arrived, we unpacked the Chinese masks, printed them with the ALG logo and 

NIOSH markings, and re-boxed them into Patriot Mask packaging with ‘Made in USA’ written 

on it.”); Exhibit H, Hutson Decl. at ¶ 7 (“I witnessed ALG Health employees putting Chinese 

respirators in ALG boxes and labeling them as ‘Made in USA.’”). 

37. In other instances, the products advertised using the statements described in 

Paragraph 32 undergo some finishing in the United States, but still incorporate all Chinese 

materials. Exhibit G, Morlock Decl. at ¶ 20 (“From the beginning and at all times, all our masks 

and mask-making materials came from China.”); Exhibit H, Hutson Decl. at ¶¶ 11-12 (“During 

my time at ALG, the company had some capacity to make masks on a very small scale, but never 

enough to cover the orders the company received. To the extent ALG did make some masks in 

the United States, all the materials used to make the masks were imported from China.”); Exhibit 

N, Feeney Decl. at ¶ 28 (“Maybe 20% of the masks ALG sold were made in Ohio; all the 

materials used to make those masks were imported.”). 

38. Therefore, Defendants’ express or implied representations that its PPE products 

are all or virtually all made in the United States are false. 

39. In August 2021, Defendants placed a notice on their website announcing a 

voluntary stop-sale of all NIOSH-certified products pending resolution of a NIOSH 

nonconformance investigation. Exhibit O. 

40. Despite this notice, Defendants continued to market their products as MUSA, and 

NIOSH-certified N95s,5 and sell them to consumers. Exhibit G, Morlock Decl. at ¶¶ 50-53 

5 NIOSH recorded the NIOSH stylized logo with and without text, as well as the certification 

marks N95, N99, N100, P95, P100, and the term “NIOSH-approved,” with the U.S. Patent and 

Trademark Office. NIOSH permits manufacturers to use these certification marks only if they 

are NIOSH-approval holders because of their products satisfying the NIOSH’s regulatory 

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(“Eventually, in summer 2021, NIOSH ordered us to stop selling. Mr. Harmon buried a 

disclaimer on his website about the stop sale, but would tell people on the phone who asked 

about it that it was not a big deal . . . Mr. Harmon never stopped selling masks; he told us the 

stop-sale only applied to ALG Health and he could continue to sell masks through Axis LED.”); 

Exhibit N, Feeney Decl. at ¶ 36 (“Despite the August 2021 NIOSH stop-sale, Mr. Harmon 

continued to sell respirators with NIOSH markings.”). 

41. In January 2022, NIOSH published a notice on the cdc.gov website stating ALG 

voluntarily rescinded all NIOSH respirator approvals and ALG respirators bearing the referenced 

approval numbers could no longer be manufactured, assembled, sold, or distributed. Exhibit P.6 

42. Despite this notice, Defendants continued to market certain of the identified 

products as MUSA and NIOSH-certified N95s, and sell these products to consumers. Exhibit Q, 

Images of ALG Respirators Purchased February 2022; Exhibit R, ALG Instagram Feed (Feb. 3, 

2022); Exhibit S, ALG Specification Sheet (Jan. 27, 2022). 

43. Based on the facts and violations of law alleged in this Complaint, Plaintiff has 

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

Commission because, among other things, Defendants have engaged in their unlawful acts and 

practices repeatedly over at least a five-year period, Defendants have engaged in their 

unlawful acts and practices willfully and knowingly, and Defendants have continued their 

unlawful activities despite a previous FTC investigation, and investigations by other federal 

government agencies. 

standards set forth in 42 C.F.R. Part 84. See 

https://www.cdc.gov/niosh/npptl/usernotices/counterfeitResp.html. 

6 See also NIOSH Respiratory Protective Device Information (Jan. 11, 2022), 

https://www.cdc.gov/niosh/npptl/resources/pressrel/letters/respprotect/CA-2022-1042.html. 

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The Individual Defendant’s Knowledge 

44. At all times relevant to this Complaint, Defendant Harmon had sole responsibility 

for creating, developing, approving, implementing, overseeing, or ensuring compliance with 

company policies and procedures. 

45. At all times relevant to this Complaint, Defendant Harmon had sole responsibility 

for and control and decision-making authority over product marketing and labeling, including 

U.S.-origin claims. 

46. In 2016, Defendant Harmon acknowledged he was aware of and understood FTC 

guidance and caselaw providing that marketers must not make unqualified MUSA claims unless 

the advertised products are all or virtually all MUSA. 

47. As described in Paragraphs 21-22, in 2016, Defendant Harmon specifically 

agreed, among other things, to market his products consistent with the FTC guidance and 

caselaw providing that marketers must not make unqualified MUSA claims unless the advertised 

products are all or virtually all MUSA in order to resolve an FTC investigation into allegations 

he deceptively marketed his products. 

48. In 2017, Defendant Harmon acknowledged receipt of a letter from FTC staff 

reiterating the FTC guidance and caselaw referenced in Paragraph 47, and Defendant Harmon’s 

agreement to market his products consistent with such guidance. 

49. At all times relevant to this Complaint, Defendant Harmon was aware that ALG 

products incorporated significant imported content and, in many cases, were wholly imported. 

50. Indeed, Defendant Harmon’s name and contact information appears on 

commercial invoices for imported, completed masks. Exhibit N, Feeney Decl. at pp. 8-11. 

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51. Despite this knowledge, Defendant Harmon repeatedly asserted in marketing 

materials and on labels that such products were all or virtually all and, in some cases, 100% 

MUSA. 

52. Moreover, Defendant Harmon repeatedly published articles and marketing 

materials stating or implying ALG products were safer or otherwise superior to imported 

products. 

Violations of the FTC Act 

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

acts or practices in or affecting commerce.” 

54. Misrepresentations or deceptive omissions of material fact constitute deceptive 

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

55. Section 12 of the FTC Act, 15 U.S.C. § 52, prohibits the dissemination of any 

false advertisement in or affecting commerce for the purpose of inducing, or which is likely to 

induce, the purchase of food, drugs, devices, services, or cosmetics. For purposes of Section 12, 

facemasks sold by Defendants are “devices” as defined in Section 15(d) of the FTC Act, 15 

U.S.C. § 55(d). 

56. Enacted on December 27, 2020, the COVID-19 Act provides for civil penalties 

for any person who engages in a deceptive act or practice in or affecting commerce in violation 

of Section 5(a) of the FTC Act, 15 U.S.C. § 45(a), that is associated with the treatment, cure, 

prevention, mitigation, or diagnosis of COVID-19 during the public health emergency declared 

on January 31, 2020, pursuant to Section 319 of the Public Health Service Act. Pub. L. No. 116-

260, Title XIV, § 1401(b)(1). 

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57. The COVID-19 Act provides that “[a] violation of subsection (b) shall be treated 

as a violation of a rule defining an unfair or deceptive act or practice as described under Section 

18(a)(1)(B) of the [FTC] Act,” 15 U.S.C. § 57a(a)(1)(B). 

58. Section 5(m)(1)(A) of the FTC Act, 15 U.S.C. § 45(m)(1)(A), as implemented 

by 16 C.F.R. § 1.98(d), authorizes this Court to award monetary civil penalties of up to $46,517 

for each violation of Section 5(a) of the FTC Act pursuant to the COVID-19 Act. 

Count I 

FTC Act Violation – MUSA Claims for LED Products 

59. In numerous instances since 2016, in connection with the advertising, marketing, 

promotion, offering for sale, or sale of LED lights, Defendants have represented, directly or 

indirectly, expressly or by implication, that their goods are all or virtually all made in the United 

States, or assembled in the United States. 

60. In truth and in fact, in numerous instances, Defendants’ LED products are wholly 

imported, or incorporate significant imported materials or subcomponents. 

61. Therefore, Defendants’ representations as set forth in Paragraph 59 are false, 

misleading, or unsubstantiated, and constitute deceptive acts or practices in violation of Section 

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

Count II 

FTC Act Violation – MUSA Claims for PPE Products 

62. In numerous instances since 2020, in connection with the advertising, marketing, 

promotion, offering for sale, or sale of PPE, Defendants have represented, directly or indirectly, 

expressly or by implication, that their goods are all or virtually all made in the United States. 

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63. On or after December 27, 2020, Defendants made the representations set forth in 

Paragraph 62, which are associated with the treatment, cure, prevention, mitigation, or diagnosis 

of COVID-19. 

64. In truth and in fact, in numerous instances, Defendants’ PPE products are wholly 

imported, or incorporate significant imported materials or subcomponents. 

65. Therefore, Defendants’ representations as set forth in Paragraphs 62-63 are false, 

misleading, or unsubstantiated, and constitute deceptive acts or practices in violation of Sections 

5(a) and 12 of the FTC Act, 15 U.S.C. §§ 45(a), 52. 

66. Defendants committed the violations set forth in Paragraphs 62-64 with the 

knowledge required by Section 5(m)(1)(A) of the FTC Act, 15 U.S.C. § 45(m)(1)(A). 

Count III 

FTC Act Violation – Other False or Deceptive Claims for PPE Products 

67. In numerous instances since 2020, in connection with the advertising, marketing, 

promotion, offering for sale, or sale of PPE, Defendants have represented, directly or indirectly, 

expressly or by implication, that: 

a. Because they are all or virtually all made in the United States, Defendants’ 

PPE products are safer or provide superior protection from COVID-19 

than imported products; and 

b. Defendants sell NIOSH-certified, U.S.-origin N95 respirators. 

68. On or after December 27, 2020, Defendants made the representations set forth in 

Paragraph 67, which are associated with the treatment, cure, prevention, mitigation, or diagnosis 

of COVID-19. 

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69. In truth and in fact, in numerous instances, because Defendants’ PPE products are 

wholly imported, or incorporate significant imported materials or subcomponents, Defendants’ 

PPE products are not safer nor do they provide superior protection from COVID-19 than 

imported products. 

70. In truth and in fact, Defendants do not sell NIOSH-certified, U.S.-origin N95 

respirators. 

71. Therefore, Defendants’ representations as set forth in Paragraphs 67-68 are false, 

misleading, or unsubstantiated, and constitute deceptive acts or practices in violation of Sections 

5(a) and 12 of the FTC Act, 15 U.S.C. §§ 45(a), 52. 

72. Defendants committed the violations set forth in Paragraphs 67-69 with the 

knowledge required by Section 5(m)(1)(A) of the FTC Act, 15 U.S.C. § 45(m)(1)(A). 

Violations of the MUSA Labeling Rule 

73. Effective August 13, 2021, the MUSA Labeling Rule, 16 C.F.R. Part 323, 

prohibits marketers from labeling products as “Made in USA” unless: (1) the final assembly or 

processing of the product occurs in the United States; (2) all significant processing that goes into 

the product occurs in the United States; and (3) all or virtually all ingredients or components of 

the product are made and sourced in the United States. 16 C.F.R. § 323.2. 

74. The MUSA Labeling Rule also provides that to the extent any mail order catalog 

or mail order promotional material includes a seal, mark, tag, or stamp labeling a product “Made 

in USA,” such label must comply with the requirements of 16 C.F.R. §323.2. 16 C.F.R. § 323.3. 

75. For purposes of the MUSA Labeling Rule, “Made in USA” is defined as “any 

unqualified representation, express or implied, that a product or service, or a specified 

component thereof, is of U.S. origin, including, but not limited to, a representation that such 

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product or service is ‘made,’ ‘manufactured,’ ‘built,’ ‘produced,’ ‘created,’ or ‘crafted’ in the 

United States or in America, or any other unqualified U.S.-origin claim.” 16 C.F.R. § 323.1. 

76. A violation of the MUSA Labeling Rule constitutes an unfair or deceptive act or 

practice in violation of Section 5(a) of the FTC Act, 15 U.S.C. §45(a). 15 U.S.C. § 57a(d)(3) and 

16 C.F.R. § 323.4. 

77. Section 5(m)(1)(A) of the FTC Act, 15 U.S.C. § 45(m)(1)(A), as implemented 

by 16 C.F.R. § 1.98(d), authorizes this Court to award monetary civil penalties of up to 

$46,517 for each violation of the MUSA Labeling Rule. 

Count IV 

MUSA Labeling Rule Violations 

78. In numerous instances since August 13, 2021, Defendants have placed MUSA 

labels on products containing significant imported components. 

79. In numerous instances since August 13, 2021, Defendants have included images 

of the labels on products described in Paragraph 78, as well as stylized seals labeling such 

products MUSA, in mail order promotional material, including on the alg-health.com website 

and social media platforms. 

80. Defendants applied the labels described in Paragraphs 78-79 to products 

containing ingredients or components that are not all or virtually all made and sourced in the 

United States. 

81. Defendants’ practices as alleged in Paragraphs 78-80 violate the MUSA Labeling 

Rule, 16 C.F.R. §§ 323.2, 323.3, and therefore are unfair or deceptive acts or practices in 

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

Page 20 of 23 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

Case: 3:22-cv-01389 Doc #: 1 Filed: 08/05/22 21 of 23. PageID #: 21 

82. Defendants committed the violations set forth in Paragraphs 78-80 with the 

knowledge required by Section 5(m)(1)(A) of the FTC Act, 15 U.S.C. § 45(m)(1)(A). 

Consumer Injury 

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

injury as a result of Defendants’ violations of the FTC Act and the MUSA Labeling Rule. 

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

harm the public interest. 

Prayer for Relief 

Wherefore, Plaintiff requests that the Court: 

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

MUSA Labeling Rule by Defendants; 

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

C. Award Plaintiff monetary civil penalties from Defendants for each violation 

of Section 5 pursuant to the COVID-19 Act; 

D. Award Plaintiff monetary civil penalties for each violation of the MUSA Labeling 

Rule; and 

E. Award any additional relief as the Court determines to be just and proper. 

Respectfully submitted, 

Dated: August 5, 2022 BRIAN M. BOYNTON 

Principal Deputy Attorney General 

Civil Division 

ARUN G. RAO 

Deputy Assistant Attorney General 

Page 21 of 23 
 

 

 

 

 

 

 

 

 

 

 

 

 

Case: 3:22-cv-01389 Doc #: 1 Filed: 08/05/22 22 of 23. PageID #: 22 

MICHELLE M. BAEPPLER 

First Assistant United States Attorney 

Northern District of Ohio 

s/Brendan F. Barker 

BRENDAN F. BARKER (IL: 6299039) 

Assistant United States Attorney 

United States Court House 

801 West Superior Avenue, Suite 400 

Cleveland, OH 44113 

(216) 622-3795 

(216) 522-2404 (facsimile) 

Brendan.Barker@usdoj.gov 

GUSTAV W. EYLER 

Director 

Consumer Protection Branch 

LISA K. HSIAO 

Assistant Director 

s/ Matthew A. Robinson 

MATTHEW A. ROBINSON 

ELLEN BOWDEN MCINTYRE 

Trial Attorneys Appearing Pursuant to 28 U.S.C. § 517 

Consumer Protection Branch 

U.S. Department of Justice 

P.O. Box 386 

Washington, DC 20044 

matthew.a.robinson@usdoj.gov 

Phone: (202) 305-4342 

ellen.bowden.mcintyre@usdoj.gov 

Phone: (202) 451-7731 

Attorneys for Plaintiff 

UNITED STATES OF AMERICA 

Of Counsel: 

FEDERAL TRADE COMMISSION 

JAMES A. KOHM 

Associate Director 

Page 22 of 23 
 

 

 

 

 

Case: 3:22-cv-01389 Doc #: 1 Filed: 08/05/22 23 of 23. PageID #: 23 

Division of Enforcement 

LAURA KOSS 

Assistant Director 

Division of Enforcement 

s/ Julia Solomon Ensor 

JULIA SOLOMON ENSOR 

Attorney 

Federal Trade Commission 

600 Pennsylvania Ave., N.W. 

Mail Stop CC-9528 

Washington, D.C. 20580 

Tel.: 202-326-2377 

Fax: 202-326-3197 

jensor@ftc.gov 

Page 23 of 23 
JS 44 (Rev. 3/22) Case: 3:22-cv-01389 Doc #: 1-1 Filed: 08/05/22 1 of 3. PageID #: 24 CIVIL COVER SHEET

The JS 44 civil cover sheet and the information contained herein neither replace nor supplement the filing and service of pleadings or other papers as required by law, except as 

provided by local rules of court. This form, approved by the Judicial Conference of the United States in September 1974, is required for the use of the Clerk of Court for the 

purpose of initiating the civil docket sheet. (SEE INSTRUCTIONS ON NEXT PAGE OF THIS FORM.) 

I. (a) PLAINTIFFS DEFENDANTS 

United States of America Axis Led Group, LLC; ALG-Health LLC; Adam J. Harmon 

(b) County of Residence of First Listed Plaintiff County of Residence of First Listed Defendant Williams 

(EXCEPT IN U.S. PLAINTIFF CASES) (IN U.S. PLAINTIFF CASES ONLY) 

NOTE: IN LAND CONDEMNATION CASES, USE THE LOCATION OF

THE TRACT OF LAND INVOLVED. 

(c) Attorneys (Firm Name, Address, and Telephone Number) Attorneys (If Known)

Brendan F. Barker, Assistant U.S. Attorney 

801 W. Superior Ave., STE 400, Cleveland, OH44113 

II. 

✖ 1 

Ph:(216) 622-3795 

BASIS OF JURISDICT

U.S. Government 

Plaintiff 

I

3 

ON (Place an “X” in One Box Only) 

Federal Question 

(U.S. Government Not a Party) 

III. CITIZENSHIP OF PRIN

(For Diversity Cases Only) 

PTF 

Citizen of This State 1 

CIPA

DEF 

1 

L PARTIES (Place an “X” in One Box for Plaintiff 

and One Box for Defendant) 

PTF 

Incorporated or Principal Place 4 

of Business In This State 

DEF 

4 

2 U.S. Government 

Defendant 

4 Diversity 

(Indicate Citizenship of Parties in Item III) 

Citizen of Another State 2 2 Incorporated and Principal Place 

of Business In Another State 

5 5 

Citizen or Subject of a 

Foreign Country 

3 3 Foreign Nation 6 6 

IV. NATURE OF SUIT (Place an “X” in One Box Only) Click here for: Nature of Suit Code Descriptions. 

CONTRACT TORTS FORFEITURE/PENALTY BANKRUPTCY OTHER STATUTES 

110 Insurance PERSONAL INJURY PERSONAL INJURY 625 Drug Related Seizure 422 Appeal 28 USC 158 375 False Claims Act 

120 Marine 310 Airplane 365 Personal Injury - of Property 21 USC 881 423 Withdrawal 376 Qui Tam (31 USC 

130 Miller Act 315 Airplane Product Product Liability 690 Other 28 USC 157 3729(a)) 

140 Negotiable Instrument Liability 367 Health Care/ 400 State Reapportionment 

150 Recovery of Overpayment 320 Assault, Libel & Pharmaceutical INTELLECTUAL 

PROPERTY RIGHTS 

410 Antitrust 

& Enforcement of Judgment Slander Personal Injury 

820 Copyrights 

430 Banks and Banking 

151 Medicare Act 330 Federal Employers’ Product Liability 

830 Patent 

450 Commerce 

152 Recovery of Defaulted Liability 368 Asbestos Personal 

835 Patent 

-

Abbreviated 

460 Deportation 

Student Loans 340 Marine Injury Product 

New Drug Application 

470 Racketeer Influenced and 

(Excludes Veterans) 345 Marine Product Liability 

840 Trademark 

Corrupt Organizations 

153 Recovery of Overpayment Liability PERSONAL PROPERTY LABOR 

880 Defend Trade Secrets 

480 Consumer Credit 

of Veteran’s Benefits 350 Motor Vehicle 370 Other Fraud 710 Fair Labor Standards 

Act of 2016 

(15 USC 1681 or 1692) 

160 Stockholders’ Suits 355 Motor Vehicle 371 Truth in Lending Act 485 Telephone Consumer 

190 Other Contract Product Liability 380 Other Personal 720 Labor/Management SOCIAL SECURITY Protection Act 

195 Contract Product Liability 360 Other Personal Property Damage Relations 861 HIA (1395ff) 490 Cable/Sat TV 

196 Franchise Injury 385 Property Damage 740 Railway Labor Act 862 Black Lung (923) 850 Securities/Commodities/ 

362 Personal Injury - Product Liability 751 Family and Medical 863 DIWC/DIWW (405(g)) Exchange 

Medical Malpractice Leave Act 864 SSID Title XVI 890 Other Statutory Actions 

REAL PROPERTY CIVIL RIGHTS PRISONER PETITIONS 790 Other Labor Litigation 865 RSI (405(g)) 891 Agricultural Acts 

210 Land Condemnation 440 Other Civil Rights Habeas Corpus: 791 Employee Retirement 893 Environmental Matters 

220 Foreclosure 441 Voting 463 Alien Detainee Income Security Act FEDERAL TAX SUITS 895 Freedom of Information 

230 Rent Lease & Ejectment 442 Employment 510 Motions to Vacate 870 Taxes (U.S. Plaintiff Act 

240 Torts to Land 443 Housing/ Sentence or Defendant) 896 Arbitration 

245 Tort Product Liability Accommodations 530 General 871 IRS—Third Party 899 Administrative Procedure 

290 All Other Real Property 445 Amer. w/Disabilities - 535 Death Penalty IMMIGRATION Act/Review or Appeal of 

Employment Other: 462 Naturalization Application Agency Decision

446 Amer. w/Disabilities - 540 Mandamus & Other 465 Other Immigration 950 Constitutionality of 

Other 550 Civil Rights Actions State Statutes 

448 Education 555 Prison Condition 

560 Civil Detainee -

Conditions of 

Confinement 

26 USC 7609 

✖

V. ORIGIN (Place an “X” in One Box Only) 

✖ 1 Original 2 Removed from 3 Remanded from 4 Reinstated or 5 Transferred from 6 Multidistrict 8 Multidistrict 

Proceeding State Court Appellate Court Reopened Another District Litigation - Litigation -

(specify) Transfer Direct File 

Cite the U.S. Civil Statute under which you are filing (Do not cite jurisdictional statutes unless diversity): 

15 U.S.C. § 45

VI. CAUSE OF ACTION Brief description of cause: 

Defendants are alleged to have falsely marketed, labeled, and sold products as being "Made in the United States" 

CHECK IF THIS IS A CLASS ACTION DEMAND $ CHECK YES only if demanded in complaint: 

COMPLAINT: UNDER RULE 23, F.R.Cv.P. JURY DEMAND: 

VII. REQUESTED IN 

Yes ✖ No 

VIII. RELATED CASE(S) 

(See instructions): IF ANY JUDGE DOCKET NUMBER 

DATE SIGNATURE OF ATTORNEY OF RECORD 08/05/2022 s/Brendan F. Barker

FOR OFFICE USE ONLY 

RECEIPT # AMOUNT APPLYING IFP JUDGE MAG. JUDGE 
Case: 3:22-cv-01389 Doc #: 1-1 Filed: 08/05/22 2 of 3. PageID #: 25 

UNITED STATES DISTRICT COURT 

NORTHERN DISTRICT OF OHIO 

I. Civil Categories: (Please check one category only ). 

1. ✔ General Civil

 2. Administrative Review/Social Security

 3. Habeas Corpus Death Penalty 

*If under Title 28, §2255, name the SENTENCING JUDGE:

 CASE NUMBER: 

II. RELATED OR REFILED CASES. See LR 3.1 which provides in pertinent part: "If an action is filed or removed to this Court 

and assigned to a District Judge after which it is discontinued, dismissed or remanded to a State court, and 

subsequently refiled, it shall be assigned to the same Judge who received the initial case assignment without regardfor 

the place of holding court in which the case was refiled. Counsel or a party without counsel shall be responsible for 

bringing such cases to the attention of the Court by responding to the questions included on the Civil Cover Sheet." 

This action: is RELATED to another PENDING civil case is a REFILED case was PREVIOUSLY REMANDED

If applicable, please indicate on page 1 in section VIII, the name of the Judge and case number. 

III. In accordance with Local Civil Rule 3.8, actions involving counties in the Eastern Division shall be filed at any of the 

divisional offices therein. Actions involving counties in the Western Division shall be filed at the Toledo office. For the 

purpose of determining the proper division, and for statistical reasons, the following information is requested. 

ANSWER ONE PARAGRAPH ONLY. ANSWER PARAGRAPHS 1 THRU 3 IN ORDER. UPON FINDING WHICH 

PARAGRAPH APPLIES TO YOUR CASE, ANSWER IT AND STOP. 

(1) Resident defendant. If the defendant resides in a county within this district, please set forth the name of such 

county Williams COUNTY: 

Corporation For the purpose of answering the above, a corporation is deemed to be a resident of that county in 

which it has its principal place of business in that district. 

(2) Non-Resident defendant. If no defendant is a resident of a county in this district, please set forth the county 

wherein the cause of action arose or the event complained of occurred. 

COUNTY: 

(3) Other Cases. If no defendant is a resident of this district, or if the defendant is a corporation not having a principle 

place of business within the district, and the cause of action arose or the event complained of occurred outside 

this district, please set forth the county of the plaintiff's residence. 

COUNTY: 

IV. The Counties in the Northern District of Ohio are divided into divisions as shown below. After the county is 

determined in Section III, please check the appropriate division. 

EASTERN DIVISION

 

 AKRON (Counties: Carroll, Holmes, Portage, Stark, Summit, Tuscarawas and Wayne)

(Counties: Ashland, Ashtabula, Crawford, Cuyahoga, Geauga, CLEVELAND Lake, Lorain, Medina and Richland) 

YOUNGSTOWN (Counties: Columbiana, Mahoning and Trumbull) 

WESTERN DIVISION 

✔ TOLEDO (Counties: Allen, Auglaize, Defiance, Erie, Fulton, Hancock, Hardin, Henry,

Huron, Lucas, Marion, Mercer, Ottawa, Paulding, Putnam, Sandusky, Seneca

 VanWert, Williams, Wood and Wyandot) 
JS 44 Reverse (Rev. 3/22) Case: 3:22-cv-01389 Doc #: 1-1 Filed: 08/05/22 3 of 3. PageID #: 26 

INSTRUCTIONS FOR ATTORNEYS COMPLETING CIVIL COVER SHEET FORM JS 44 

Authority For Civil Cover Sheet 

The JS 44 civil cover sheet and the information contained herein neither replaces nor supplements the filings and service of pleading or other papers as 

required by law, except as provided by local rules of court. This form, approved by the Judicial Conference of the United States in September 1974, is 

required for the use of the Clerk of Court for the purpose of initiating the civil docket sheet. Consequently, a civil cover sheet is submitted to the Clerk of 

Court for each civil complaint filed. The attorney filing a case should complete the form as follows: 

I.(a) Plaintiffs-Defendants. Enter names (last, first, middle initial) of plaintiff and defendant. If the plaintiff or defendant is a government agency, use 

only the full name or standard abbreviations. If the plaintiff or defendant is an official within a government agency, identify first the agency and then 

the official, giving both name and title.

 (b) County of Residence. For each civil case filed, except U.S. plaintiff cases, enter the name of the county where the first listed plaintiff resides at the 

time of filing. In U.S. plaintiff cases, enter the name of the county in which the first listed defendant resides at the time of filing. (NOTE: In land 

condemnation cases, the county of residence of the "defendant" is the location of the tract of land involved.) 

(c) Attorneys. Enter the firm name, address, telephone number, and attorney of record. If there are several attorneys, list them on an attachment, noting 

in this section "(see attachment)". 

II. Jurisdiction. The basis of jurisdiction is set forth under Rule 8(a), F.R.Cv.P., which requires that jurisdictions be shown in pleadings. Place an "X" 

in one of the boxes. If there is more than one basis of jurisdiction, precedence is given in the order shown below. 

United States plaintiff. (1) Jurisdiction based on 28 U.S.C. 1345 and 1348. Suits by agencies and officers of the United States are included here. 

United States defendant. (2) When the plaintiff is suing the United States, its officers or agencies, place an "X" in this box. 

Federal question. (3) This refers to suits under 28 U.S.C. 1331, where jurisdiction arises under the Constitution of the United States, an amendment 

to the Constitution, an act of Congress or a treaty of the United States. In cases where the U.S. is a party, the U.S. plaintiff or defendant code takes 

precedence, and box 1 or 2 should be marked. 

Diversity of citizenship. (4) This refers to suits under 28 U.S.C. 1332, where parties are citizens of different states. When Box 4 is checked, the 

citizenship of the different parties must be checked. (See Section III below; NOTE: federal question actions take precedence over diversity 

cases.) 

III. Residence (citizenship) of Principal Parties. This section of the JS 44 is to be completed if diversity of citizenship was indicated above. Mark this 

section for each principal party. 

IV. Nature of Suit. Place an "X" in the appropriate box. If there are multiple nature of suit codes associated with the case, pick the nature of suit code 

that is most applicable. Click here for: Nature of Suit Code Descriptions. 

V. Origin. Place an "X" in one of the seven boxes. 

Original Proceedings. (1) Cases which originate in the United States district courts. 

Removed from State Court. (2) Proceedings initiated in state courts may be removed to the district courts under Title 28 U.S.C., Section 1441. 

Remanded from Appellate Court. (3) Check this box for cases remanded to the district court for further action. Use the date of remand as the filing 

date. 

Reinstated or Reopened. (4) Check this box for cases reinstated or reopened in the district court. Use the reopening date as the filing date. 

Transferred from Another District. (5) For cases transferred under Title 28 U.S.C. Section 1404(a). Do not use this for within district transfers or 

multidistrict litigation transfers.

Multidistrict Litigation – Transfer. (6) Check this box when a multidistrict case is transferred into the district under authority of Title 28 U.S.C. 

Section 1407. 

Multidistrict Litigation – Direct File. (8) Check this box when a multidistrict case is filed in the same district as the Master MDL docket. 

PLEASE NOTE THAT THERE IS NOT AN ORIGIN CODE 7. Origin Code 7 was used for historical records and is no longer relevant due to 

changes in statute. 

VI. Cause of Action. Report the civil statute directly related to the cause of action and give a brief description of the cause. Do not cite jurisdictional 

statutes unless diversity. Example: U.S. Civil Statute: 47 USC 553 Brief Description: Unauthorized reception of cable service. 

VII. Requested in Complaint. Class Action. Place an "X" in this box if you are filing a class action under Rule 23, F.R.Cv.P. 

Demand. In this space enter the actual dollar amount being demanded or indicate other demand, such as a preliminary injunction. 

Jury Demand. Check the appropriate box to indicate whether or not a jury is being demanded. 

VIII. Related Cases. This section of the JS 44 is used to reference related pending cases, if any. If there are related pending cases, insert the docket 

numbers and the corresponding judge names for such cases. 

Date and Attorney Signature. Date and sign the civil cover sheet. 
Case: 3:22-cv-01389 Doc #: 1-2 Filed: 08/05/22 1 of 1. PageID #: 27 

Fri Jan 28 2022 

Entity#: 2425435 

Filing Type: DOMESTIC LIMITED LIABILITY COMPANY 

Original Filing Date: 09/02/2015 

Location: ---

Business Name: AXIS LED GROUP, LLC 

Status: Active 

Exp. Date: -

Agent/Registrant Information 

ADAM J. HARMON 

6810 AVERY MUIRFIELD RD 

DUBLIN OH 43017 

09/02/2015 

Active 

Filings 

Filing Type Date of Filing Document ID 

----~ I 

Frank LaRose 

I ~ s~ o6 sf.Au, I 

ARTICLES OF ORGNZTN/DOM. PROFIT LIM.LIAB. CO. 09/02/2015 201524503592 

UNITED STATES OF AMERICA 

STATE OF OHIO 

OFFICE OF SECRETARY OF STATE 

I, Frank LaRose, Secretary of State of the State of Ohio, do hereby certify that this is a list 

of all records approved on this business entity and in the custody of the Secretary of State. 

Witness my hand and the seal of the 

Secretary of State at Columbus, 

Ohio this 28th of January, A.D. 2022 

Ohio Secretary of State 

Exhibit A

Page 1 of 1 
.----ES I 

Frank LaRose 

I '9iiw 8~ " &au I 

Case: 3:22-cv-01389 Doc #: 1-3 Filed: 08/05/22 1 of 1. PageID #: 28 

Wed Feb 16 2022 

Entity#: 4486681 

Filing Type: DOMESTIC LIMITED LIABILITY COMPANY 

Original Filing Date: 06/12/2020 

Location: ---

Business Name: ALG-HEALTH LLC 

Status: Active 

Exp. Date: -

Agent/Registrant Information 

STEPHEN F HUBBARD 

650 W FIRST ST 

DEFIANCE OH 43512 

02/08/2021 

Active 

Filings 

Filing Type Date of Filing Document ID 

OHIO LLC - ARTICLES OF ORGANIZATION 06/12/2020 202016402250 

SUBSEQUENT AGENT APPOINT/LIMITED/LIABILTY/PARTNERS 02/08/2021 202103903570 

UNITED STATES OF AMERICA 

STATE OF OHIO 

OFFICE OF SECRETARY OF STATE 

I, Frank LaRose, Secretary of State of the State of Ohio, do hereby certify that this is a list 

of all records approved on this business entity and in the custody of the Secretary of State. 

Witness my hand and the seal of the 

Secretary of State at Columbus, 

Ohio this 16th of February, A.D. 2022 

Ohio Secretary of State 

Exhibit B

Page 1 of 1 
 

 

O · 

Case: 3:22-cv-01389 Doc #: 1-4 Filed: 08/05/22 1 of 9. PageID #: 29 

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Exhibit C 

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Case: 3:22-cv-01389 Doc #: 1-4 Filed: 08/05/22 2 of 9. PageID #: 30 

Exhibit C 

p. 2 of 9
AXIS 

LED GROUP 

Case: 3:22-cv-01389 Doc #: 1-4 Filed: 08/05/22 3 of 9. PageID #: 31 

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Exhibit C 

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••• 

Case: 3:22-cv-01389 Doc #: 1-4 Filed: 08/05/22 4 of 9. PageID #: 32 

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Case: 3:22-cv-01389 Doc #: 1-4 Filed: 08/05/22 5 of 9. PageID #: 33 

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Exhibit C 

p. 5 of 9
Factory Direct Wholesale LED 

Lighting 

Energy Efficient LED 

Case: 3:22-cv-01389 Doc #: 1-4 Filed: 08/05/22 6 of 9. PageID #: 34 

Axis LED Group http://www.axisledlights.com/ 

1 of 4 11/2/2016 8:52 AM 

Exhibit C 

p. 6 of 9
AXIS LEO GROUP 

Backed by the resources of one of 

the largest LED manufacturers in the 

world, Axis LED Lights offers 

contractors, facility managers, 

designers, distributors and other 

lighting professionals the 

opportunity to specify and select 

LEDs that feature both affordability 

and high performance. 

Who We Are 

About Us Products Contact Us 

._ , 

1 l 

,__ ) 

Case: 3:22-cv-01389 Doc #: 1-4 Filed: 08/05/22 7 of 9. PageID #: 35 

Axis LED Group http://www.axisledlights.com/ 

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Exhibit C 

p. 7 of 9
AXIS LEO GROUP 

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Case: 3:22-cv-01389 Doc #: 1-4 Filed: 08/05/22 8 of 9. PageID #: 36 

Axis LED Group http://www.axisledlights.com/ 

3 of 4 11/2/2016 8:52 AM 

Exhibit C 

p. 8 of 9
AXIS About Us Products Contact Us LEO GROUP 

Featured Products 

A 

AXIS LED GROUP 

ABOUTUS PRODUCTS CONTACTUS 

Case: 3:22-cv-01389 Doc #: 1-4 Filed: 08/05/22 9 of 9. PageID #: 37 

Axis LED Group http://www.axisledlights.com/ 

4 of 4 11/2/2016 8:52 AM 

Exhibit C 

p. 9 of 9
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Case: 3:22-cv-01389 Doc #: 1-5 Filed: 08/05/22 1 of 3. PageID #: 38 

U.S. Department of Justice 

UNICOR 

Federal Prison Industries, Inc. 

July 6, 2016 

Axis LED Group, LLC 

6810 Avery Muirfield Rd 

Dublin,,OH 43017 

Subject: BAA/TAA Compliance Letter 

Dear Adam, 

This letter is to confirm that UNICOR has entered into a contract manufacturing agreement with Axis 

LED to assemble lighting fixtures at our plant in Marion, IL. UNICOR hereby certifies that these 

lighting fixtures will comply with the Buy American Act, FAR 52.225 ("the Act"): 

These lighting fixtures are considered Commercially Available Off the Shelf (COTS) products under 

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ALG Part Numbers Assembled by FPI: 

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PT-T8-ILT2-13W-BC :BALLAST COMPATIBLE 

PT-T8-ILT4-15W-BC :BALLAST COMPATIBLE 

PT-T8-ILT4-18W-BC :BALLAST COMPATIBLE 

PT-T8-IL T4-20W-BC :BALLAST COMPATIBLE 

PT-T8-IL T2-12W-PP :PLUG & PLAY 

PT-T8-ILT3-12W-PP :PLUG & PLAY 

PT-T8-ILT4-12W-PP :PLUG & PLAY 

PT-T8-ILT4-14W-PP :PLUG & PLAY 

PT-T8-ILT4-16W-PP :PLUG & PLAY 

PT-T8-0LT2-10W :EXTERNAL DRIVER 

PT-T8-0LT4-15W :EXTERNAL DRIVER 

PT-T8-0L T4-18W :EXTERNAL DRIVER 

PT-T8-0L T4-22W :EXTERNAL DRIVER 

Exhibit D 

p. 1 of 3
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Case: 3:22-cv-01389 Doc #: 1-5 Filed: 08/05/22 2 of 3. PageID #: 39 

LED PANELS: COLOR TEMPS 3000K - 5000K. 

PP-1X4-40W :FLAT PANEL 

PP-2X2-30W :FLAT PANEL 

PP-2X2-40W :FLAT PANEL 

PP-2X2-60W :FLAT PANEL 

PP-2X4-50W :FLAT PANEL 

PP-2X4-75W :FLAT PANEL 

PTD-2x2-30W :TROFFER KIT 

PTD-2x2-56W :TROFFER KIT 

PTD-2x4-36W :TROFFER KIT 

PTD-2x4-36W :TROFFER KIT 

PTL-2x2-30W :TROFFER LAY-IN 

PTL-2x2-36W :TROFFER LAY-IN 

PTL-2x4-36W :TROFFER LAY-IN 

PTL-2x4-50W :TROFFER LAY-IN 

LED HIGH BAY 

ALG-HB-110W :HIGH BAY 

ALG-HB-160W :HIGH BAY 

ALG-HB-220W :HIGH BAY 

ALG-HB-320W :HIGH BAY 

FurtherGuidance: 

A COTS item is defined by the FAR as a "Commercial Item" sold in "substantial quantities" in the 

commercial marketplace: and offered to the Government, under a contract or subcontract at any tier, 

without modification. in the same form in which it is sold in the commercial marketplace.1 

If an End Product is characterized as a COTS Item under the FAR, the component test is waived and 

the supply or material is deemed a Domestic End Product for BAA/TAA compliance if it is simply 

"manufactured" in the United States.2 

The FAR defines "Place of Manufacture" as "the place where an end product is assembled out of 

components, or otherwise made or processed from raw materials into the finished product that is 

to be provided to the Govemment."3 

I FAR ~2.!01. FAR ~52.225-1 

2 FAR *12.505(a): ~25.003. ~251 OO(n)(3): *2510 l(a)(2) 

3 f AR *52.225-18 

Exhibit D 

p. 2 of 3
 

 

 

 

 

Case: 3:22-cv-01389 Doc #: 1-5 Filed: 08/05/22 3 of 3. PageID #: 40 

Please let me know if you have any questions or concerns. 

Program Manager 

UNICOR, FPI 

400 First Street, NW 

Washington, DC 20534 

Phone: 202-305-3734 

Cell: 202-438-5951 

Chuck.Darrin@usdoj.gov 

Exhibit D 

p. 3 of 3
Bureau of Consumer Protection 

Division of Enforcement 

Julia Solomon Ensor 

Attorney 

Emai I: jensor@ftc.gov 

Direct Dial: (202) 326-2377 

VIAFEDEX 

Adam Harmon, President 

Axis LED Group, LLC 

6810 A very Road 

Dublin, OH 43017 

Dear Mr. Harmon: 

UNITED ST ATES OF AMERICA 

FEDERAL TRADE COMMISSION 

WASHINGTON, D.C. 20580 

January 18, 2017 

We received your submissions on behalf of Axis LED Group, LLC, also d/b/a Patriot 

Tube ("Axis" or the "Company"). During our review, we raised concerns that certain marketing 

materials may have overstated the extent to which Axis makes products, including LED tubes, in 

the United States. Specifically, although certain of Axis's tubes are assembled in the United 

States, those products incorporate significant imported content. 

In the Company's submissions, Axis provided a certificate stating that certain products 

qualify as "Domestic End Products" under the Buy American Act, see 41 U.S.C. §§ 8301-8305 

("BAA"). As you know, BAA establishes price preferences for domestic end products and 

construction materials in government acquisitions, and defines those terms as they are used in 

that limited context. 1 Although truthful claims that products are BAA-compliant convey useful 

information to government purchasers, such claims directed to non-governmental consumers 

likely convey an unqualified "Made in USA" claim.2 

As we discussed, unqualified "Made in USA" or "Built in USA" claims on marketing 

materials likely suggest to consumers that all products advertised in those materials are "all or 

1 See 48 CFR § 25.003 (stating that for purposes of BAA, "domestic end product[s]" and 

"domestic construction material[s]" include, among other things, certain manufactured products 

or materials where either the cost of the components mined, produced, or manufactured in the 

United States exceeds 50% of the cost of all components, or the product or material is a 

commercially available off-the-shelf item). 

2 See FTC Policy Statement on Deception, 103 F.T.C. 174 (1984) (appended to In re Cliffdale 

Assocs., Inc., 103 F.T.C. 110, 177-78 (1984) ("When representations or sales practices are 

targeted to a specific audience, the Commission determines the effect of the practice on a 

reasonable member of that group."). 

Page 1 of2 

Case: 3:22-cv-01389 Doc #: 1-6 Filed: 08/05/22 1 of 2. PageID #: 41 

Exhibit E 

p. 1 of 2
virtually all" made in the United States. The FTC's Enforcement Policy Statement on "Made in 

USA" and Other U.S. Origin Claims (the 'Policy Statement") provides that '[a] product that is 

all or virtually all made in the United States will ordinarily be one in which all significant parts 

and processing that go into the product are of U.S. origin. In other words, where a product is 

labeled or otherwise advertised with an unqualified 'Made in USA' claim, it should contain only 

a de minimis, or negligible, amount of foreign content."3 

The Policy Statement further explains that"' Assembled in USA' claims should be 

limited to those instances where the product has undergone its principal assembly in the United 

States and that assembly is substantial. In addition, a product should be last substantially 

transformed in the United States to properly use an 'Assembled in USA' claim."4 

To avoid deceiving consumers, you explained that Axis implemented a remedial action 

plan to clarify its representations. The plan included: (1) replacing all affected "Made in USA" 

claims on Axis marketing materials with "Assembled in the USA" claims; and (2) qualifying 

"Buy American Act Compliant" claims on marketing materials not specifically targeted at 

government consumers with "Assembled in the USA" claims. 

Based on your actions and other factors, the staff has decided not to pursue this 

investigation any further. This action should not be construed as a determination that there was 

no violation of Section 5 of the Federal Trade Commission Act, 15 U.S.C. § 45. The 

Commission reserves the right to take such further action as the public interest may require. If 

you have any questions, you can reach me at (202) 326-2377. 

_; 

Julia Solomon Ensor 

Staff Attorney 

3 Federal Trade Commission, Issuance of Enforcement Policy Statement on "Made in USA" and 

Other US Origin Claims, 62 Fed. Reg. 63756, 63768 (Dec. 2, 1997). 

4 Id. at 63770. 

Page 2 of2 

Case: 3:22-cv-01389 Doc #: 1-6 Filed: 08/05/22 2 of 2. PageID #: 42 

Exhibit E 

p. 2 of 2
~ PATRIOT 

;;ai? '-7UBE 

Axis LED's product lines offer the highest qualit y product at low 

direct prices. Assembled in USA, DLC listed, and UL rated products. 

AXIS 

LED GROUP 

Energy Efficient LED Tubes & Panels 

contact@alg-USA.com I www.ALG-USA.com I www.patriotledtubes.com 

Exhibit F 

p. 1 of 16 

Case: 3:22-cv-01389 Doc #: 1-7 Filed: 08/05/22 1 of 16. PageID #: 43 
■ '-!..fr ~ ~ PATRIOT 

~ \Cl ~ USE f.\~L§ 

Company Profile 

Welcome to Axis LED Lights, a better way to buy direct. Your source for the future of lighting. Our high quality 

LED chips and patented driver technology encapsulated in an aluminum body illuminates up to 145 lumens per 

watt directionally at 240 degrees through our superior shatterproof lens. 50,000 hours of cost saving, energy 

reducing, eco-friendly lighting that's DLC listed and UL rated with less than .01 % failure rate ... now that's smart! 

You can't afford to wait any longer. The friendly and knowledgeable staff at Axis LED are committed to customer 

service and guarantee satisfaction. Axis team members are trusted logistics experts in the lighting industry who 

will go the extra mile to ensure quality consulting, easy order processing, rapid turnaround and delivery from 

multiple U.S. warehouse locations. Contact a team member today to discuss Axis LED volume discounts and 

credit terms. 

The LED lighting revolution with Axis is a better way to buy direct. Through strategic planning and business partnership, Axis has created a new segment to LED pricing and manufacturing possibilities. Axis LED's products 

lines assembled in USA offer the highest quality product at low direct prices. assembled in USA, DLC listed, and 

UL rated products. With a minimum 40% discount over the competition you'll realize a sound return on investment 

like never before. 

www.ALG-USA.com Phone: 240.510.5712 I contact@alg-USA.com e 

Exhibit F 

p. 2 of 16 

Case: 3:22-cv-01389 Doc #: 1-7 Filed: 08/05/22 2 of 16. PageID #: 44 
Table of Contents 

01 PATRIOT LED TUBE (Works with or without a ballast!) e 

02 PATRIOT LED LINEAR HIGH BAY e 

03 PATRIOT LED PANEL (Edge Lit Flat Panel} e 

04 PATRIOT LED TUBE (Plug & Play Series) e 

05 LED TS TUBE WITH EXTERNAL DRIVER SYSTEM e 

06 PATRIOT LED TROFFER DOOR e 

07 PATRIOT T5 LED TUBES e 

08 PATRIOT TROFFER LAY-IN e 

09 PATRIOT UBEND LED TUBE e 

10 4 FT LED TS TU BE (34 7V) 

11 4 FT LED GLASS TS TU BE 

12 ALPHA LED PLUG & PLAY TUBE 

13 ALPHA LED FLAT PANEL (Edge Lit Flat Panel} 

14 ALPHA HYPRID LED TUBE (Works with or without a ballast) 

15 LEDT5 TUBE 

16 LED REFRIGERATION LIGHT 

17 LED FASTFIT T5 TUBE 

18 S FT LED TS UBE 

19 LED TS TUBE EXTERNAL 

20 LED LINEAR HIGH BAY 

21 LED STRIPS 

22 ALPHA RETROFIT KIT DOOR 

23 ALPHA TROFFER (Led Troffer) 

e Phone: 240.510.5712 I contact@alg-USA.com 

04 

04 

05 

05 

06 

06 

07 

07 

08 

09 

09 

10 

10 

11 

11 

12 

12 

13 

13 

14 

14 

15 

15 

www.ALG-USA.com 

Exhibit F 

p. 3 of 16 

Case: 3:22-cv-01389 Doc #: 1-7 Filed: 08/05/22 3 of 16. PageID #: 45 
■ '-!..fr ~ ~ PATRIOT 

~ \Cl ~ USE f.\~L§ 

Color Temperature 2700K to 5000K 

Beam Angle 300 Degrees 

Color Consistency 4 Steps 

CRI >80 

Opertion Temperature -30°C to 40°C 

Efficiency with ballast More than 110 LPW 

Efficiency without ballast More than 125 LPW 

Input Voltage with ballast 100-277VAC, 347V 

Input Voltage without ballast 100-277VAC 

Frequency 50-60Hz 

Power Factor More than 0.99 

Rated Life 50,000 hours 

Model Wattage umens LxWxD Inch 

2Y-H2-110WXDZ 110 12300 23.8"x12.6"x3.62" 

2Y-H5-160NXDZ 160 18520 23.8"x17.3"x3.62" 

PATRIOT LED TUBE 

Works with or without a ballast! 

The PATRIOT TB LED tube serves as a special energy efficient replacement for all traditional fluorescent TB lamps. 

Designed to operate on all existing rapid start, instant start, 

programmed start, and emergency fixture ballasts ... or simply no ballast at all. 

Features: 

■ Patriot Tube can work both with or without a ballast 

■ A fantastic replacement "plug and play" tube or retrofit kit 

■ Compatible with over 90 percent of all North 

American electronic ballasts 

■ The versatility of the Patriot Tube supports massive 

projects with different types of ballasts 

■ Input voltage up to AC100-277V/347V with ballast 

and AC100- 277V without ballast 

■ Suitable for damp or dry environments 

■ UL, ETL, DLC, NSF Qualified 

■ Globally Patented Technology 

■ 5 Year Manufacturer's Warranty -(Opti:>nal 1 O Year arranty avaiable) 

PATRIOT LED LINEAR 

HIGH BAY 

This Patriot LED High Bay is a brand new replacement solution for fluorescent linear high bay in warehouses, garage 

locations and any other commercial and industrial applications. 

Advantage: 

■ More than 130 L/W 

■ CRI> 80 

■ Dimrnable Driver. 

■ Input voltage can be 

AC100-277V 

■ Reduces energy con 

sumption up to 60%. 

■ Suitable for damp location 

www.ALG-USA.com Phone: 240.510.5712 I contact@alg-USA.com 0 

Exhibit F 

P- 4 of 16 

Case: 3:22-cv-01389 Doc #: 1-7 Filed: 08/05/22 4 of 16. PageID #: 46 
PATRIOT LED PANEL 

Edge Lit Flat Panel 

General illumination typically used to replace 2x2 and 2x4 fluorescent troffers. The Patriot Panel is designed to lay in drop 

ceilings in offices, schools, showrooms, airports, retail locations, and healthcare facilities. Ultra modern design with an industry leading 110 lumens per watt, the ALG PATRIOT PANEL 

is the ideal fluorescent lay-in replacement. 

Features: 

■ Edge-lit LED array with translucent diffuser provides 

uniform illumination 

■ Ultra-slim Aluminum Frame - <0.5inch 

■ Custom color temps available 

■ UL, cUL, TUV, DLC 4.0 listed 

■ LM-79, and IES available upon request 

■ 100,000 hour L?0 lifespan 

■ Lumen efficacy is greater than 1301/w lumen/watt 

■ External UL Listed Class-2 Constant Current Driver 

■ Universal Voltage: 100-277V. *100-382V available 

■ Multiple mounting options 

■ Suitable for damp locations 

■ High Power factor -.99 

PATRIOT LED TUBE 

Plug & Play Series 

The Patriot LED "Plug & Play" tube can work with specific 

TS instant- start, rapid-start, programmed-start, dimmingstart ballasts and existing emergency battery backup 

equipment Patriot P&P tube also works with some 

magnetic ballasts. 

Features: 

■ The LED tube is a fantastic direct replacement "plug 

and play" tube 

■ Compatible with over 90 percent of all North American 

electronic ballasts 

■ Glass-free for use in food areas and refrigerated food displays 

■ Input voltage up to AC100-277V/34 7V with ballast 

■ Wide 300 Degrees Beam Angle 

■ No UV emmission 

■ Suitable for damp or dry environments 

C, Phone: 240.510.5712 I contact@alg-USA.com 

Color Temperature 

Beam Angle 

CRI 

Opertion Temperature 

Efficiency 

Input Voltage 

Power Factor 

Rated Life 

Input Frequency 

Color Temperature 

Beam Angle 

Color Consistency 

CRI 

Opertion Temperature 

Efficiency with ballast 

Input Voltage with ballast 

2700K to SOOOK 

120 Degrees 

>80 

-20°c to so•c 

More than 110 LPW 

100-277VAC, •347 Available 

More than 0.99 

Rated Life 100,000 hours 

S0/ 60Hz 

2700K to SOOOK 

300 Degrees 

4 Steps 

>80 

-30°c to 40°C 

More than 120 LPW 

100-27 7VAC, 347 V 

www.ALG-USA.com 

Exhibit F 

P- 5 of 16 

Case: 3:22-cv-01389 Doc #: 1-7 Filed: 08/05/22 5 of 16. PageID #: 47 
■ '-!..fr ~ ~ PATRIOT 

~ \Cl ~ USE f.\~L§ 

Color Temperature 4000K to SOOOK 

CRI > 80 LED TB TUBE 

Operation Temperature -20°c to so•c 

Input Voltage AC100-277V with External Driver System 

Frequency S0-60Hz 

Power Factor More than 0.99 

Rated Life 50,000 hours 

Housing Aluminum 

LED Type 72 pieces of SMD 2835 

The Patriot TB Tube with External Driver can dramatically 

reduce energy usage up to 70% providing significantly lower 

operating costs. The special circuit design avoids the single 

broken LED influence problem. Utilizes high efficiency class 2 

constant current driver. One driver for 1, 2, 3, or 4 LED tubes 

available. 

Color Temperature 2700K to SOOOK 

Beam Angle 180 degree 

Color Consistency 4 steps 

CRI More than 80 

www.ALG-USA.com 

PATRIOT LED 

TROFFER DOOR 

Advantage: 

■ QJick Installation for each troffer which only takes five rrinutes. 

■ 0-10V dimmable function help to reduce operation cost. 

■ 1301/w lumens per watt help to reduce payback period 

of energy saving. 

■ 100000 hours working time and 7 year warranty. 

Frequency S0-60Hz 

Power Factor More than 0.99 

Rated Life 100,000 hours 

Phone: 240.510.5712 I contact@alg-USA.com C, 

Exhibit F 

P- 6 of 16 

Case: 3:22-cv-01389 Doc #: 1-7 Filed: 08/05/22 6 of 16. PageID #: 48 
PATRIOT TS LED TUBES 

w/ External Driver System 

Color Temperature 2700K to 5000K 

Beam Angle 180 Degrees 

CRI >80 

Operation Temperature -30°c to 40°C 

Efficiency with ballast More than 110 LPW 

Efficiency without ballast More than 125 LPW 

Input Voltage with ballast 100-277VAC, 347V 

Input Voltage without ballast 00-277VAC 

Power Factor More than 0.99 

Rated Life Rated Life 50,000 hours 

50,000 hours LED Type SMT2835 

Housing Aluminum 

Color Consistency 4 Steps 

PATRIOT TROFFER 

LAY-IN 

Advantage: 

■ QJick Installation for each troffer which only takes five minutes. 

■ 0-10V dimmable function help to reduce operation cost 

■ 110 lumens per watt help to reduce payback period 

of energy saving. 

■ 100000 hours working time and 7 year warranty. 

Color Temperature 2700K to 5000K 

Beam Angle 180 degree 

Color Consistency 4 steps 

CRI More than 80 

Operation Temperature -30-40C 

Efficiency with ballast More than 110 LPW 

Input Voltage with ballast 100-277VAC 

LED T5 system with external driver. The LED T5 system 

replaces traditional T5 systems. One driver for 1, 2, 3, or 

4, tubes available. 

Frequency 50-60Hz 

Power Factor More than 0. 99 

Rated Life 100,000 hours 

Led SMT 2835 

Type Aluminum+PC 

Housing 

f) Phone: 240.510.5712 I contact@alg-USA.com www.ALG-USA.com 

Exhibit F 

P- 7 of 16 

Case: 3:22-cv-01389 Doc #: 1-7 Filed: 08/05/22 7 of 16. PageID #: 49 
■ '-!..fr ~ ~ PATRIOT 

~ \Cl ~ USE f.\~L§ 

Feature: 

® ~ tiglit,rig 

..,,_ ""' ti!.£!! 

■ Patriot Tube can work both with or without a ballast 

■ A fantastic replacement "plug and play" tube or retrofit kit 

■ Compatible with over 90 percent of all North 

■ American electronic ballasts 

■ The versatility of the Patriot Tube supports massive 

projects with different types of ballasts 

■ Input voltage up to AC100-277V/347V with ballast and 

AC100- 277V without ballast 

■ Suitable for damp or dry environments 

■ UL, ETL, NSF Qualified 

■ Globally Patented Technology 

■ 5 Year Manufacturer's Warranty 

Color Temperature 2700K to SOOOK 

CRI > 80 

Operation Temperature -20°c to so•c 

Input Voltage AC100-277V 

Patriot Ubend 

LED Tube 

The PATRIOT TB LED tube serves as a special energy efficient replacement for all traditional fluorescent TB lamps. 

Designed to operate on all existing rapid start, instant 

start, programmed start, and emergency fixture ballasts ... 

or simply no ballast at all. 

Color Temperature 2700K to SOOOK 

Beam Angle 300 Degrees 

Color Consistency 4 steps 

CRI > 80 

Operation Temperature -30°C to 40°C 

Efficiency with ballast More than llOLPW 

Efficiency without ballast More than 125 LPW 

Input Voltage with ballast 100-277VAC, 347V 

Input Voltage without ballast 100-277VAC 

Frequency S0-60Hz 

Power Factor More than 0.99 

Rated Life 50,000 hours 

LED Type SMT2835 

Housing Aluminum 

ALG MAGNETIC 

STRIP RETROFIT KIT 

The LED Magnetic Troffer Retrofit Kit can work with existing 

2x2 & 2x4 troffers. Easy installation. 

Advantage: 

■ High Lumen Efficiency 

■ Easy installation 

■ Reduces energy consumption up to 60% 

■ No UV emission and no mercury 

■ 5 Year Manufacturer's Warranty 

■ Suitable for dry and damp environments 

Power Factor More than 0.99 

Rated Life 50,000 hours 

Power Supply Efficiency 90% 

Frequency S0-60Hz 

www.ALG-USA.com Phone: 240.510.5712 I contact@alg-USA.com C) 

Exhibit F 

p. 8 of 16 

Case: 3:22-cv-01389 Doc #: 1-7 Filed: 08/05/22 8 of 16. PageID #: 50 
Color Temperature 2700K to SOOOK 

CRI > 80 

Operation Temperature -20°c to so•c 

Input Voltage AC100-347V 

Color Temperature 3000K to SOOOK 

CRI > 80 

Operation Temperature -20°c to so•c 

Input Voltage AC100-277V, 347V 

4 FT LED TB TUBE <

347V) 

Direct Wire 

4 foot LED TS system with internal driver. The LED TS 

system replaces traditional TS systems. Comes single or 

double ended input. 

Frequency S0-60Hz 

Power Factor More than 0.99 

Rated Life 50,000 hours 

Power Supply Efficiency 90% 

4 FT LED GLASS TB 

TUBE 

4 foot LED TS system with internal driver. The LED TS 

system replaces traditional TS systems. High Output 

150LPW - All Glass Tube Housing. Shatter proof PET 

Coating. 

Beam Angle 320 Degrees 

Power Factor More than 0. 99 

Rated Life 50,000 hours 

Power Supply Efficiency 90% 

f) Phone: 240.510.5712 I contact@alg-USA.com www.ALG-USA.com 

Exhibit F 

P- 9 of 16 

Case: 3:22-cv-01389 Doc #: 1-7 Filed: 08/05/22 9 of 16. PageID #: 51 
■ g ~ TR/OT /\LPHAL::D 

AXIS " T_l.:!.1¥}§ I,, ' LEO OROUF> 

ALPHA LED PLUG & 

PLAY TUBE 

The Alpha LED tube can work with specific TB instant- start, 

rapid-start, programmed-start, dimming-start ballasts and 

existing emergency battery backup equip- ment. Alpha also 

works with some magnetic ballasts. 

Features: 

■ The Alpha LED tube is a fantastic direct replacement 

"plug and play" tube 

■ Compatible with over 90 percent of all North American 

electronic ballasts 

■ Glass-free for use in food areas and refrigerated food 

displays 

■ Input voltage up to AC100-277V /34 7V with ballast 

■ Wide 300 Degrees Beam Angle 

■ No UV emmission 

■ Suitable for damp or dry environments 

■ TB aluminum housing with plastic lens 

■ 5 Year Manufacturer's Warranty 

-Optional 10 Year Warranty available 

ALPHA LED FLAT PANEL 

Edee Lit Flat Panel 

General illumination typically used to replace 2x2 and 2x4 

fluorescent troffers. The Alpha Panel is designed to lay in 

drop ceilings in offices, schools, showrooms, airports, retail 

locations, and healthcare facilities. Ultra modern design with 

an industry leading 110 lumens per watt, the Alpha® Flat 

Panel is the ideal fluorescent lay-in replacement. 

Features: 

■ Edge-lit LED array with translucent diffuser provides 

uniform illumination 

■ Ultra-slim Aluminum Frame - <0.5inch 

■ Custom color temps available 

■ UL, cUL, TUV, DLC 3.1 listed 

■ LM-79, and IES available upon request 

■ 100,000 hour L70 lifespan 

■ Lumen efficacy is greater than 110 lumen/watt 

Color Temperature 2700K to SOOOK 

Beam Angle 300 Degrees 

Color Consistency 4 Steps 

CRI > 80 

Operation Temperature -30°c to 40°C 

Efficiency with ballast More than 120 LPW 

Input Voltage with ballast 100-277VAC, 347V 

Frequency S0-60Hz 

Power Factor More than 0.99 

Rated Life 50,000 hours 

LED Type SMT2835 

Color Temperature 2700K to SOOOK 

Beam Angle 120 Degrees 

CRI > 80 

Operation Temperature -20°c to so•c 

Efficiency More than 110 LPW 

Input Voltage 100-277VAC, •347 Available 

Power Factor More than 0.99 

wwwALG-USA.com Phone: 240.510.5712 I contact@alg-USA.com Cl!) 

Exhibit F 

p. 10 of 16 

Case: 3:22-cv-01389 Doc #: 1-7 Filed: 08/05/22 10 of 16. PageID #: 52 
_________________ ~LPHAL::D~ !A.TR/OT ~ - .. TUBE 11-o~u, uu AXIS 

L EO GF-IOU? 

Features: 

■ Alpha Tube can work both with a without a ballast 

■ A fantastic replacement "plug and play" tube or retrofit kit 

■ Corrpatible with over 90+ percent of all North Arrerican ballasts 

■ The versatility of the "Magic Tube" supports massive projects 

with different types of ballasts 

■ Input voltage up toAC100-277V/347V with ballast and 

AC100- 277V without ballast 

■ Suitable for damp or dry environments 

■ UL, ETL, DLC, NSF Qualified 

■ Globally Patented Technology 

■ 5 Year Manufacturer's Warranty 

-Optional 10 Year Warranty available 

■ Rotatable end caps available. 

LED T5 system with external driver. The LED T5 system 

replaces traditional T5 systems. One driver for 1, 2, 3, or 

4, tubes available. 

ALPHA HYBRID 

LED TUBE 

Works with or without a ballast! 

The Alpha TS LED tube serves as a special energy effi .. 

cient replacement for all traditional fluorescent TS lamps. 

Designed to operate on all existing rapid start, instant start, 

programmed start, and emergency fixture ballasts AND 

some magnetic ballast... or simply no ballast at all. 

Color Temperature 2700K to 5000K 

Beam Angle 180 Degrees 

CRI > 80 

Operation Temperature .. 30°c to 40°C 

Efficiency with ballast More than 110 LPW 

Efficiency without ballast More than 125 LPN 

Input Voltage with ballast 100-277VAC, 347V 

Input Voltage without ballast 00-277VAC 

Power Factor More than 0.99 

Rated Life Rated Life 50,000 hours 

50,000 hours LED Type SMT2835 

Housing Aluminum 

Color Consistency 4 Steps 

ALPHA LED TS TUBE 

w/ External Driver System 

Color Temperature 2700K to 5000K 

Beam Angle 180 Degrees 

CRI >80 

Operation Temperature .. 30°c to 40°C 

Efficiency with ballast More than 110 LPW 

Efficiency without ballast More than 125 LPW 

Input Voltage with ballast 100-277VAC, 347V 

Input Voltage without ballast 00-277VAC 

Power Factor More than 0.99 

Rated Life Rated Life 50,000 hours 

CD Phone: 240.510.5712 I contact@alg-USA.com wwwALG-USA.com 

Exhibit F 

p. 11 of 16 

Case: 3:22-cv-01389 Doc #: 1-7 Filed: 08/05/22 11 of 16. PageID #: 53 
■ g ~ TR/OT /\LPHAL::D 

AXIS " T_l.:!.1¥}§ I,, ' LEO OROUF> 

LED Refrigeration Light 

The LED Refrigeration light can dramatically reduce energy 

usage up to 75% providing significantly lower operating costs. 

This light has been designed to offer high quality directional 

illumination with 50,000 hour life expectancy. 

Features: 

■ 50,000 hour life expectancy 

■ IP65 rated light module for use in commerical 

refrigerators and freezers 

■ Dramatically improves look for any food or 

merchan- dise being displayed 

■ Energy efficient design significantly reduces cost of 

ownership- savings up to 75% 

■ Light diffuser contains no glass providing zero risk of 

glass breakage 

■ Instant start in cold environments 

■ Available in 2ft, 3ft, 4ft, 5ft & 6ft for vertical and 

horizontal installation 

■ Mercury and lead free 

■ Local utility incentives may be available 

■ Binned diodes for color uniformity 

■ Clear and frosted cover available 

■ 5 Year Manufacturer's Warranty 

-Optional 10 Year Warranty available 

LED FastFit TS TUBE 

The LED T5 FastFit tube can work with specific T5 electronic ballast This T5 FastFit is a direct replacement for T5HO 

fluorescent tubes. 

Features: 

■ High Lumen Efficiency 

■ Compatible with programmable start T5HO electronic ballast 

■ Reduces energy consumption up to 60% 

■ No UV emission and no mercury 

■ 5 Year Manufacturer's Warranty 

■ Suitable for dry and damp environments 

~ .. - ... -~-,,. ... -,. .. -.. --,. .... ,.. .. .. ········'"·"'·-······· ... -.... .. 

Color Temperature 2700K to SOOOK 

Beam Angle 120 Degrees 

CRI > 80 

Operation Temperature -20°c to so•c 

Efficiency More than 110 LPW 

Input Voltage 100-382VAC 

Frequency S0-60Hz 

Power Factor 92% 

Rated Life 50,000 hours 

LED Type SMT2835 

~ ""' "" 

s ,.__, 

...... ' .... 

Color Temperature 2700K to SOOOK 

CRI > 80 

Operation Temperature -20°c to so•c 

Input Voltage AC100-277V 

wwwALG-USA.com Phone: 240.510.5712 I contact@alg-USA.com '9 

Exhibit F 

p. 12 of 16 

Case: 3:22-cv-01389 Doc #: 1-7 Filed: 08/05/22 12 of 16. PageID #: 54 
_________________ ~LPHAL::D~ !A.TR/OT ~ - . TUBE 11-o~u, uu AXIS 

L EO GF-IOU? 

The TB Tube with External Driver can dramatically reduce 

energy usage up to 70% providing significantly lower operating costs. The special circuit design avoids the single broken LED influence problem. Utilizes high efficiency class 

2 constant current driver. One driver for 1, 2, 3, or 4 LED 

tubes available. 

B FT LED TB TUBE 

8 foot LED TS system with external driver. The LED TS 

system replaces traditional TB systems. Comes standard 

single pin. AC-Direct. 

Color Temperature 

CRI 

Operation Temperature 

Input Voltage 

Frequency 

Power Factor 

Rated Life 

Power Supply Efficiency 

LED TB TUBE 

EXTERNAL 

Color Temperature 

CRI 

Operation Temperature 

Input Voltage 

Frequency 

Power Factor 

Rated Life 

Housing 

2700K to SOOOK 

> 80 

-20°c to so•c 

AC100-277V 

S0-60Hz 

More than 0.99 

50,000 hours 

90% 

2700K to SOOOK 

> 80 

-20°c to so•c 

AC100-277V 

S0-60Hz 

More than 0.99 

50,000 hours 

Aluminum 

LED Type 72 pieces ofSMD 2835 

Luminaire Efficiency llSLPW 

Power Factor Efficiency 90% 

ce Phone: 240.510.5712 I contact@alg-USA.com wwwALG-USA.com 

Exhibit F 

p. 13 of 16 

Case: 3:22-cv-01389 Doc #: 1-7 Filed: 08/05/22 13 of 16. PageID #: 55 
■ g ~ TR/OT /\LPHAL::D 

AXIS " T_l.:!.1¥}§ I,, ' LEO OROUF> 

LED Linear High Bay 

This led linear high bay is a brand new replacement solution 

for fluorescent linear high bay in warehouse, garage locations 

and any other commercial and industrial applications. 

Advantage: 

■ Lumen Output more than 130 lumens per watt 

■ CRI more than 80 Espend dimmable driver. 

■ Input voltage can be AC100-277V 

■ Reduces energy consumption up to 60%. 

■ 5 years lifespan 

■ Surface mounting installation 

■ Suitable for damp location UL and DLC 

■ Glass-free 

LED Strips 

This strip light is mainly for commercial use. It can be used 

in warehouse, office, garage display shops and otther comercial applications 

Advantage: 

■ Lumen Output more than 120 lumens per watt 

■ CRI more than 80 

■ Espend dimmable driver 

■ Input voltage can beAC100-277V 

■ Reduces energy consumption upto 60% 

■ 5 years lifespan 

■ Surface mounting installation 

■ Suitable for damp location Model 

■ UL and DLC 2Y-ST4FTHL 

■ Glass-free 2Y-ST4FTLW 

Wattage Lumens LxWxD inch 

24W 2880 48"X3.3S"X3.56" 

36W 4320 48"X3.3S"X3.56" 

wwwALG-USA.com Phone: 240.510.5712 I contact@alg-USA.com C, 

Exhibit F 

p.14of16 

Case: 3:22-cv-01389 Doc #: 1-7 Filed: 08/05/22 14 of 16. PageID #: 56 
_________________ ~LPHAL::D~ !A.TR/OT ~ - . TUBE 11-o~u, uu AXIS 

L EO GF-IOU? 

Advantage: 

ALPHA Retrofit Kit Door 

Advantage: 

■ Quick Installation for each retrofit kit which only ta<es 

five ninutes. 

■ 0-1 OV dimmable function help to reduce operation cost 

■ 135 lumens per watt help to reduce payback period of 

energy saving. 

■ 100000 hours working time and 7 years warranty. 

Color Temperature 2700K to 5000K 

Beam Angle 120 degree 

Color Consistency 4 steps 

CRI More than 80 

Operation Temperature -30-40C 

Efficiency with ballast More than 135 LPW 

Frequencey 50-60 HZ 

Power Factor More than 0.99 

Rated Life SMT 2835 

Housing Aluminum+PC 

ALPHA Troffer LedTroffer 

Color Temperature 2700K to 5000K 

CRI More than 80 

Operation Temperature .30•.40•c 

Input Voltage with ballast 1---227V AC100-382V 

Frequency 50-60Hz 

Power Factor More than 0.99 

Rated Life 7 years hours 

Housing Aluminum+PC 

Beam Angle 120 degree 

Color Consistency 4 steps 

Efficiency with ballast More than 135 LPW 

Led Type SMT 2835 

■ Quick Installation for each retrofit kit which only takes five minutes. 

■ 0-10V dimmable function help to reduce operation cost 

■ 135 lumens per watt help to reduce payback period of energy saving. 

■ 100000 hours working time and 7 years warranty. 

CL' Phone: 240.510.5712 I contact@alg-USA.com wwwALG-USA.com 

Exhibit F 

p. 15 of 16 

Case: 3:22-cv-01389 Doc #: 1-7 Filed: 08/05/22 15 of 16. PageID #: 57 
~ PATRIOT J\.LPHAL=D 

~~L§ ;a~ ;ruse ¥, 

9 Axis LED Group 6810 Avery Rd. Dublin, OH 43017 

~ 240.510.5712 

~ contact@alg-USAcom 

@ wwwALG-USAcom, www.patriotledtubes.com 

Exhibit F 

p. 16 of 16 

Case: 3:22-cv-01389 Doc #: 1-7 Filed: 08/05/22 16 of 16. PageID #: 58 
Case: 3:22-cv-01389 Doc #: 1-8 Filed: 08/05/22 1 of 14. PageID #: 59 

DECLARATION OF BURT MORLOCK 

PURSUANT TO 28 U.S.C. § 1746 

1. My name is Burt Morlock. I am over 18 years of age and live in Ohio. I have 25 years of 

packaging experience. 

2. I have personal knowledge of the facts stated in this declaration, and if called as a 

witness, I could and would competently testify to the facts stated herein. 

3. In January 2020, Adam Harmon hired me as a warehouse manager for Axis LED, LLC, a 

company that sold LED light fixtures in Defiance, Ohio. 

4. From the moment I started working there, I had questions. My gut said something wasn’t 

right. 

5. We got packages of lights from China with “Made in China” stickers. Mr. Harmon 

instructed me to peel the stickers off the lights, and re-box them in new boxes with 

“Patriot LED” logos and new stickers that said “Made in USA.” 

6. My first week of work, I asked if what we were doing was legal, and Mr. Harmon read 

me a letter from the FTC saying what he was doing was okay. Mr. Harmon said he 

bought the licensing rights to do this stuff. Thinking back, Mr. Harmon later showed me 

a different letter about N95 masks from NIOSH. Now I’m wondering if both letters were 

falsified; I once heard Mr. Harmon joking that his favorite software was one that allowed 

him to change PDF files. 

7. At Axis LED, we handled government contracts, and supplied hundreds of thousands of 

lights to the U.S. government. We didn’t do anything to those lights other than peel the 

“Made in China” stickers off and replace them with new “Made in USA” stickers. 

8. As far as I know, Mr. Harmon is still doing this and selling the lights to the U.S. 

government. 

Morlock Declaration Page 1 of 8 

Exhibit G 

p. 1 of 14
Case: 3:22-cv-01389 Doc #: 1-8 Filed: 08/05/22 2 of 14. PageID #: 60 

9. I never saw anyone do any manufacturing at all on these lights. Sometimes we plugged 

them in to see if they worked or swapped out power strips, but that was it. We didn’t 

make anything. 

10. We did buy boxes from Fort Wayne, Indiana, but that packaging was the only part of 

Axis LED’s lighting products that was from the USA. 

11. The Chinese LEDs were supplied by someone Mr. Harmon referred to as “James 

Industries,” with a warehouse in California. All the lights arrived at our warehouse in 

James’s name with no documentation. 

12. Around February or March of 2020, the pandemic hit, and we started selling personal 

protective equipment (PPE). 

13. Right away, we started getting shipments of KN95 masks, gloves, and gowns from China 

that we resold to consumers. These masks came from a company called “Venas,” which 

Mr. Harmon told me was a parent company to Axis LED. 

14. All the shipments came in via James Industries and were sent to Axis LED without any 

additional documentation. Mr. Harmon used several different logistics companies. 

Mostly a company called Priority One, but sometimes Uber Freight. 

15. In May of 2020, Mr. Harmon said we should start manufacturing masks. I told him we 

didn’t know anything about making respirators and manufacturing is a hard process. I 

asked numerous times about how we were going to design and make N95 respirators. He 

said, “I’ll have James do all of it.” 

16. A few weeks went by, and Mr. Harmon started showing us samples of masks. 

17. Around that time, in spring 2020, two machines showed up in the Defiance facility, along 

with fabric to make masks. Mr. Harmon said they were new machines, but they looked 

Morlock Declaration Page 2 of 8 

Exhibit G 

p. 2 of 14
Case: 3:22-cv-01389 Doc #: 1-8 Filed: 08/05/22 3 of 14. PageID #: 61 

about 10 years old. They were rusted and beat up with no manuals, no wiring diagrams, 

etc. 

18. By June or July of 2020, Mr. Harmon had approvals from NIOSH for a mask that we 

never made. 

19. Mr. Harmon told us Venas, which he said was actually Axis LED’s parent company, 

could make the masks in China. “James Industries,” the same company that supplied our 

LEDs, would bring the Chinese masks to us in the USA to sell. 

20. From the beginning and at all times, all our masks and mask-making materials came from 

China. 

21. By the summer of 2020, there were 25-30 employees in the Defiance, Ohio location and 

we were selling a lot of masks. We still had just those two mask-making machines: one 

machine to make cup-style masks, and one machine to make foldable masks. 

22. Although we talked to James and some Chinese engineers, we had zero instruction on 

how to use the mask-making machines, and they were operated very little. The machines 

had no name plates or identifying marks. 

23. When we used them, the mask-making machines took a long time. You couldn’t make 

more than 1,000 masks per day, start to finish. The machines would often break. They 

were down more than they worked. 

24. At the same time, hundreds of thousands of Chinese masks were arriving from Venas. 

As each shipment arrived, we unpacked the Chinese masks, printed them with the ALG 

logo and NIOSH markings, and re-boxed them into Patriot Mask packaging with “Made 

in USA” written on it. 

Morlock Declaration Page 3 of 8 

Exhibit G 

p. 3 of 14
Case: 3:22-cv-01389 Doc #: 1-8 Filed: 08/05/22 4 of 14. PageID #: 62 

25. Although there were some (very few) masks being made in Ohio, the vast majority were 

imported. 

26. That summer, Mr. Harmon bought or leased the building in Bryan, Ohio and he, Gayle 

Wallen, and Doug Soper started running that facility. 

27. Around that time Mr. Harmon also hired someone named Benjamin Trow with a 

company called ISO Pro to write processes and procedures for the company, but Mr. 

Harmon didn’t want to listen to anything Mr. Trow said. Eventually Mr. Trow got 

frustrated and quit. 

28. In March 2021, I went to Bryan, Ohio. Mr. Harmon had approximately 150 people there 

at that time and a bunch of machines that half-ass ran. 

29. When he moved me over to Bryan, I asked Mr. Harmon where all the standardized work 

and quality manuals Mr. Trow made were. Mr. Harmon never answered me and said all 

the tests were done by Venas. He showed me a letter, supposedly from NIOSH, saying 

Venas and ALG Health were partners and that we could use respirators produced by them 

as our own. He said we were like GM with Chevrolet and GMC. He would show this 

letter or read it to employees whenever they questioned what we were doing. 

30. The molded masks that were “made” in the Bryan facility weren’t cooked long enough; 

they didn’t hold form and were not properly made. They didn’t undergo quality tests and 

were nothing like the Chinese masks in the boxes we unpacked. 

31. All the fabric used to make the masks in Bryan was imported. James sent all the 

materials until production really ramped up, at which point Mr. Harmon would get 

materials from other places (all still imported). 

Morlock Declaration Page 4 of 8 

Exhibit G 

p. 4 of 14
Case: 3:22-cv-01389 Doc #: 1-8 Filed: 08/05/22 5 of 14. PageID #: 63 

32. I told Mr. Harmon that he couldn’t call his masks “Made in USA” because I looked it up, 

and all the materials were supposed to be from the USA or at least a majority of them. 

Mr. Harmon told me not to worry about it and he would take care of it. 

33. Probably 90% of the masks Mr. Harmon sold were brought in from China as finished 

masks. Maybe more. 

34. At one point we got an order for 700,000 masks. I told Mr. Harmon it would take forever 

to make that many masks because we could only make 1,000 masks per day. And then a 

truck showed up with finished masks. We printed our logos on those Chinese masks, and 

then sent them out to fulfill that order, which I think went to Canada. 

35. Mr. Harmon sent Chinese masks to NIOSH to get approvals. 

36. The foldable masks were the masks we actually “made” in Defiance, Ohio. I did send a 

foldable mask to NIOSH, but Mr. Harmon sent in all the other samples. 

37. We got approval from NIOSH for cup-style molded masks before we even had a machine 

from China that could make them. 

38. At one point, Mr. Harmon bought a Chinese ATX-100 machine to do some testing. That 

machine was brand new. It might be the only thing Mr. Harmon ever bought that was 

new. It did test fabric, but for a long time we didn’t have a way to actually test finished 

masks because we couldn’t put them into the machine. 

39. Eventually our contacts in China provided information so we could fully test masks, but 

we never did the frequency of testing required and didn’t keep documentation. 

40. When NIOSH did a virtual tour of our facility to give us approvals, Mr. Harmon wasn’t 

even there. None of our machines even ran during the tour. The day we had a virtual 

tour of the Defiance location was the first day that testing machine ever ran. 

Morlock Declaration Page 5 of 8 

Exhibit G 

p. 5 of 14
Case: 3:22-cv-01389 Doc #: 1-8 Filed: 08/05/22 6 of 14. PageID #: 64 

41. All we did for most of the masks we sold was take them out of the box, print the ALG 

logo and NIOSH markings, and load them into their boxes. 

42. We never had the capability to make the teal-colored N95s we sold. But we got approval 

anyway. 

43. Mr. Harmon was selling respirators PT-N95-07, PTN95-06 that had NIOSH approval, 

even though he never owned a machine that could produce them. 

44. At all times, the quality of the masks we got from China was much better than the quality 

of anything “made” in Ohio. The Chinese masks did pass the appropriate 90% filtration 

tests. 

45. The Chinese masks arrived in boxes that said KN95. We repackaged them into boxes 

that said N95 and Patriot Masks. It was wrong; like saying a Ford is a Chevy GMC 

truck. You can’t do that! 

46. Eventually Mr. Harmon got in trouble with NIOSH because they found out that the 

butterfly component of the foldable masks he told NIOSH were made in the USA was 

imported. Around then I started thinking everything was a sham. 

47. Mr. Harmon lied on the phone with NIOSH. He told them only the butterflies were from 

China, but the rest of the mask components were made in the USA. That was a lie. He 

sold millions of imported masks rebranded as Patriot Masks out of Bryan, Ohio. 

48. I am aware of at least two documents that Mr. Harmon forged and sent to a consultant to 

try to help him get out of trouble with NIOSH. 

49. After the calls with NIOSH, we had a big meeting and Mr. Harmon said he wasn’t 

dealing with James anymore. But then, a few weeks later, more masks arrived. 

Morlock Declaration Page 6 of 8 

Exhibit G 

p. 6 of 14
Case: 3:22-cv-01389 Doc #: 1-8 Filed: 08/05/22 7 of 14. PageID #: 65 

50. Eventually, in summer 2021, NIOSH ordered us to stop selling. Mr. Harmon buried a 

disclaimer on his website about the stop sale, but would tell people on the phone who 

asked about it that it was not a big deal and he would be up and running again in a few 

weeks. 

51. At that time, I asked Mr. Harmon where that letter from NIOSH was that said what we 

were doing with Venas – selling their masks as our own – was okay. He told me he lost 

it. 

52. Boxes of masks continued to arrive. They said KN95 on them, and I told Mr. Harmon he 

couldn’t call them N95s because that would be counterfeit. We got in a big argument 

because Mr. Harmon sold them anyway. 

53. Mr. Harmon never stopped selling masks; he told us the stop-sale only applied to ALG 

Health and that he could continue to sell masks through Axis LED. 

54. Mr. Harmon put stickers on boxes to block out the “Made in USA” label. At that point, 

our boxes were layered with like twelve stickers covering up all kinds of information, 

including the fact that the masks were made in China. 

55. Mr. Harmon lied to me from day one. We were all duped and lied to. I found out later 

that Mr. Harmon forged my name to a bunch of documents. 

56. When I left in October 2021, a lot of people were laid off. Looking back, I think there 

were times when Mr. Harmon wanted to do legit manufacturing, but there was no way he 

could. So, James just gave him masks and Mr. Harmon didn’t throw them out. Instead, 

he took them out of boxes, printed the ALG logo and NIOSH information, put them into 

new boxes, and sold them to consumers. At one point, Mr. Harmon’s mother, Gayle 

Morlock Declaration Page 7 of 8 

Exhibit G 

p. 7 of 14
Wallen, told me James was our friend, there was nothing wrong with what we were 

doing, and James was giving us a gift. 

57. On the day I quit or was fired or whatever you want to call it in October 2021, I saw Mr. 

Harmon parked in the handicapped spot. I told him, "you think the rules don't apply to 

you, Adam. You do what you want." 

58. Attached are six photos, Exhibits A-F, that I took in Axis/ ALG facilities during my 

employment. These photos show shipments of LEDs, masks, and materials coming in 

from China for use in Axis/ ALG products. 

I declare under penalty of perjury that the foregoing is true and correct. 

Executed on c,2. / 09 /~ ~ -Z z.. , 2022. 

Burt Morlock 

Morlock Declaration Page 8 of 8 

Case: 3:22-cv-01389 Doc #: 1-8 Filed: 08/05/22 8 of 14. PageID #: 66 

Exhibit G 

p. 8 of 14
PO~: 

C/NO.: 

QTY .. :1 PC . 

-ME A.S.: 38X26.5X19CM . 

-MADE IN CHINA 

tt 

Case: 3:22-cv-01389 Doc #: 1-8 Filed: 08/05/22 9 of 14. PageID #: 67 

Exhibit G 

p. 9 of 14

Morlock Declaration Exhibit A
COUNTRY:USA 

MANUFACTURER:ALG 

PRODUC1:PT-T81lT4-22W-40KCOLOR TEMP: A000K 

QUANTITY: 30PCS 

S\ZE: 49X9X91 N 

WEIGHT: 20LBS 

·-·-""'-

Case: 3:22-cv-01389 Doc #: 1-8 Filed: 08/05/22 10 of 14. PageID #: 68 

Exhibit G 

p. 10 of 14

Morlock Declaration Exhibit B
ATlO 

Fa - elscn Labo ra tories LLC Contact

Dani Blake 

: 7 

S . eawooa oad Salt La ke City 

UT 84123 USA 

84123 SALT LAKE CITY Utah LU !TED STATES OF AMERICA _J 

• 

• 

Ref: 9030367 Shipment Weight piece 

23.0 kg 1/2 

------ -----------

111111 1111111111111111 WAYBILL II 23 4531 6654 

Conten ts : KN95 

MRSK 

Case: 3:22-cv-01389 Doc #: 1-8 Filed: 08/05/22 11 of 14. PageID #: 69 

Exhibit G 

p. 11 of 14

Morlock Declaration Exhibit C 
roducers :Ve as e 

DongG a 

Production batch 

Model:FMN5 1 

Production Date.202 112/ 

Raw material:19.41/o o - ove 

16.1 1⁄4 melt blo n a ic 

65.4 1⁄4 Acupunc ure co o 

Size: 62*57*45cm 

igh :9.Bkg 

• 

• 'V-., 'V 

Case: 3:22-cv-01389 Doc #: 1-8 Filed: 08/05/22 12 of 14. PageID #: 70 

Exhibit G 

p. 12 of 14

Morlock Declaration Exhibit D
RKP-l20W-l20V-50K-S 

Case: 3:22-cv-01389 Doc #: 1-8 Filed: 08/05/22 13 of 14. PageID #: 71 

Exhibit G 

p. 13 of 14

Morlock Declaration Exhibit E
Venas Co.,Umlted 

Company name1 

Address: 

Attn: 

Emaln/Tel, 

AXIS LED GROUP, llC 

2953 N HONORE STREET CHICAGO, IL 60657 

843-694-6469 

ADAM@PATRIOTLED.COM 

Company name, AXIS LED GROUP, LLC 

Address: 

Attn, 

Email/Tel, 

EXW 

2106 BALTIMORE STREET DEFIANCE, OH 43512 

Adam Harmon 

843-694-6469 

PO# 

N/A 

Proforma In 

2020/9/22 

,. __ , ., ' Adam Harmon 

843-694-6469 

r ·- ADAM@PATRIOn 

P~T~ ,....., _ _. ...... .._ .. ,__._,--~--- ~•d 

30OAY NET ASAI 

The buyer Is responsible for customs clearance , tariff and related risks and expenses after the goods leave China, 

Since this products are mainly be used for the spec~I period of Covid-19 spread, So there Is no any policy about product returned ;ifter products be shlppe1 

1 Nose Clip 

2 Spon1e ~r 

3 Electrostatic cotton 

after payment be made. 

~ 

white, Plastic nose clip with double wire, length :85mm, 

wldth:7mm, thlckness:0.3mm 

white, wldth:2&0mm,60l/m2 

190KG 

200,000PCS 

501KG 

400KG 

:flliw&ch 

IUSDI 

2.81 

0.015 

4.12 

37.5 

-~ 

tuso) 

533.9 

3000 

2064.12 

15000 

James own 

warehouse I 

CHINA 

James own 

warehouse I 

CHINA 

James own 

w;irehouse 

CHINA 

James ow 

warehouse 

/ CHINA 

Case: 3:22-cv-01389 Doc #: 1-8 Filed: 08/05/22 14 of 14. PageID #: 72 

Exhibit G 

p. 14 of 14

Morlock Declaration Exhibit F
DECLARATION OF CHAD HUTSON 

PURSUANT TO 28 U.S.C. § 1746 

1. My name is Chad Hutson. I am over 18 years of age and live in Ohio. I have 25 years of 

experience working in FDA-regulated environments. 

2. I have personal knowledge of the facts stated in this declaration. and if called as a 

witness. I could and would competently testify to the facts stated herein. 

3. In February 2021. Adam Harmon hired me as VP-Operations for ALO Health, a 

company that sold respirators in Defiance. Ohio. 

4. I know all about FDA regulations, shortly after I started, I had concerns about Mr. 

Harmon's operation. including that he wasn't following a quality management system 

(QMS). 

5. The facility in Defiance did dual operations; it processed respirators and lighting 

products. I had no direct supervision over the lighting side of the business, but can 

confirm that, based on my observations, the lighting operation consisted of simply reboxing Chinese lighting products. 

6. Walking through Mr. Harmon's Bryan, OH warehouse, I routinely saw hundreds of 

thousands of KN95 respirators, all made in China. 

7. I witnessed ALG Health employees putting Chinese respirators in ALG boxes and 

labeling them as --Made in USA.·· 

8. I told Mr. Harmon he was committing fraud, and Mr. Harmon told me he had approval 

from NIOSH to do what he was doing. He showed me a letter supposedly from NIOSH. 

but the letter looked a little strange to me. It did not use terminology I would expect. For 

example, the Jetter referred to .. masks" instead of "respirators." l now believe Mr. 

Harmon forged the Jetter. 

Hutson Declaration Pagel of 3 

Scanned with CamScanner 

Case: 3:22-cv-01389 Doc #: 1-9 Filed: 08/05/22 1 of 3. PageID #: 73 

Exhibit H
9. Later, when Mr. Harmon got in trouble with NIOSH, I asked him where the letter from 

them approving his operations was, and Mr. Harmon told me he couldn't find it. 

10. It is my belief that Mr. Harmon never intended to make masks on a large scale in the 

USA. Instead, Mr. Harmon set up operations to make it look like he had USA maskmaking capacity. and then overwhelmingly sold wholly imported Chinese masks. 

1 I. During my time at ALG, the company had some capacity to make masks on a very small 

scale, but never enough to cover the orders the company received. 

12. To the extent ALG did make some masks in the United States, all the materials used to 

make the masks were imported from China. 

13. I insisted that Mr. Harmon sould not label the masks he "made" in Ohio of Chinese 

materials as "Made in USA.,. I told him maybe he could label those masks as 

"Assembled in USA," but because product components have to be from the USA to label 

the product as "Made in USA," he couldn't label a product with all Chinese components 

that way. 

14. During my time at ALG, we sold around four million masks. Probably several thousand 

of them were ;.made" in the Ohio facility. If I had to guess I would estimate there was a 

90%-10% split between the ALG masks that were wholly imported and those that were 

·•made" in Ohio. 

15. James Industries is a person in China who gave Mr. Harmon his mask-making materials 

and equipment. He was Mr. Harmon's Chinese liaison. 

16. James Industries also went by ·'James Bond" and had a colleague, also in China, who 

went by ··Roy Rogers.'· 

Scanned with CamScanner 

Case: 3:22-cv-01389 Doc #: 1-9 Filed: 08/05/22 2 of 3. PageID #: 74 

Exhibit H
I 7. James Industries operated through numerous business names including Venas, EPC, and 

All Masks. 

I 8. Everything in Mr. Harmon's facilities came in through James. from China. 

19. Mr. Harmon repeatedly told us that "regulators were too busy to worry about what he was 

doing". I indicated that I did not feel comfortable engaging in these operations, but would 

continue working toward NIOSH compliance. 

20. The operation was designed to make it look like Mr. Harmon had mask-making 

capabilities, but he did not. The mask-making machines Mr. Harmon had were Chinese 

junk; when they ran, operators were routinely shocked, and you could see electricity 

arcing from the machines One of the machines operated without an electrical panel. 

21. Ultimately NIOSH ordered ALO to stop selling masks and I immediately shut down the 

floor. That infuriated Mr. Harmon, and he continued to sell masks despite the stop-sale. 

22. I was terminated on September 16, 2021. My termination papers stated the reason for 

termination was "Irreconcilable Differences." 

I declare under penalty of perjury that the foregoing is true and correct. 

Executed on Februrary 15, 2022. 

Hutson Declaration Page 3 of 3 

Scanned with CamScanner 

Case: 3:22-cv-01389 Doc #: 1-9 Filed: 08/05/22 3 of 3. PageID #: 75 

Exhibit H
0 ~ https://www.alg-health.com 

LG lealt~ 

~ ~ \(I) • • 

Get a Quote 

419.990.6275 9 520 W. Mulberry St. 

Bryan, OH 43506 0 Monday - Friday 8:00AM - 5:00PM EST 

I • 

Manufactured in USA N95 Mask This disposable N95 masks 

in stock offers braided headbands and staple free 

attachment points. 

I 

Case: 3:22-cv-01389 Doc #: 1-10 Filed: 08/05/22 1 of 3. PageID #: 76 

Exhibit I 

p. 1 of 3
Case: 3:22-cv-01389 Doc #: 1-10 Filed: 08/05/22 2 of 3. PageID #: 77 

 

 
a face book.com/ ALGhealth/?ref=page_internal 

ALG Health 

0 Page transparency See all 

Facebook is showing information to help you 

better understand the purpose of a Page. See 

actions taken by the peop le who manage and 

post content. 

pa Page created • September 22, 2020 

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June 18, 2021 · 0 

Quality fi t testing is important when choosing an #n95facemask. Our 

products exceed set standards. 

#ppesupplies #ppesupplier #masksupplier #manufacturedinusa 

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Shop · ALG Health · N95 Masks 

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Exhibit I 

p. 3 of 3 

Case: 3:22-cv-01389 Doc #: 1-10 Filed: 08/05/22 3 of 3. PageID #: 78 
~ ➔ C 0 M face book.com/ ALGhealth/photos/ a.1760896 77 5 87248/1 7 6088014254081 / ~ ~ @ 

... ... ... 

ALG Health 

December 30, 2020 0 

We are based in NW Ohio. 

» * Im -

0 

Our phone number is 419-576-5470 

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Make sure you are dealing direct with the factory 

and not a person o r company from another state 

or country who is claiming to be us. 

r/:J Like 0 Comment 

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~ Share 

Exhibit J 

p. 1 of 3 

Case: 3:22-cv-01389 Doc #: 1-11 Filed: 08/05/22 1 of 3. PageID #: 79 
i face book.com/ ALGhealth/?ref= page_internal 

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ALG Health 

July 16 2021 ·0 

,. Like 0 Message 

Our N95 face masks are manufactured in USA designed to protect 

medical workers, first responders, military, and humanitarian workers. 

Every day that we come to work. we know we are building hospital· 

g rade N95 face masks to protect those who protect us. 

MADE IN USA 

PATRIOT 

--MASK--

rfJ Like CJ Comment ~ Share 

Exhibit J 

p. 2 of 3 

Case: 3:22-cv-01389 Doc #: 1-11 Filed: 08/05/22 2 of 3. PageID #: 80 
Home 

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Case: 3:22-cv-01389 Doc #: 1-11 Filed: 08/05/22 3 of 3. PageID #: 81 

Exhibit J 

p. 3 of 3
D YouTube alg health 

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ALG Health lntroduct1ion-Made in the USA PPE 

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ALG Health 

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An Introduction to ALG Health, the history, It's mission, and location. This video showcases the 

power of Made In America when it comes to personal protective equipment With It's new 

manufacturing location In Bryan Ohio. ALG Health Is producing N95 respirators and disposable 

masks that are 100'6 Made In the USA for our men and women first responders, medical personnel, 

military, government agency, and humanitarian efforts. Special thanks to Todd Productions for the 

development, production, and edit of the video. 

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COVID-19; How much protection do face masks offer? 

Can face masks help slow the spread of the coronavirus (SARS-CoV-2) that causes COVID-19? Yes, face masks 

combined with other preventive ... 

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p. 11 of 11
i facebook.com/ALGhealth/?ref=page_internal 

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jia Page created - September 22, 2020 

Related Pages 

• Northwest Ohio Junior G ... alt Like Sports league 

• Dave Dempsey Realtor alt Like Real Estate Agem 

@ Edgerton Chambe r of Co .. alt Like 

Community Organization 

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ALG Health 

August 6, 2021 · 0 

1it Like 0 Message 

"AMMA members answered the co untry's call for high quality, 

American-made surgical masks at the onset of the COVID-19 

pandemic. We urge HIDA to enco urage their healthca re customers to 

purchase American-made PPE and masks so t hat our heroic frontline 

workers do not have their safety put at risk by relying on foreignmade prod ucts." 

AMMAUNITEO.ORG 

AMMA Response to Health Industry Distributors Call for 

Increased Access to Low-Quality Foreign PPE 

3 Comments 

Exhibit M 

p. 1 of 2 

Case: 3:22-cv-01389 Doc #: 1-14 Filed: 08/05/22 1 of 2. PageID #: 94 
a facebook.com/ ALGhealth/?ref = page_i nternal 

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~ Dave Dempsey Realtor ,., Like Real Estate Agent 

@ Edgerton Chamber of Co ... ,., Like 

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July 22, 2021 · a 

•· Like 

0 Message 

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In addition to harming U.S. manufacturers that answered the call to 

produce PPE here, these imported products are not tested and could 

be unsafe. 

MADEINAMERJCA.COM 

PPE U.S. Manufacturers Being 'Dumped' on by 'Subsidized 

in China· $0.01 Masks 

r/) Like 0 Comment ~ Share 

Exhibit M 

p. 2 of 2 

Case: 3:22-cv-01389 Doc #: 1-14 Filed: 08/05/22 2 of 2. PageID #: 95 
 

Case: 3:22-cv-01389 Doc #: 1-15 Filed: 08/05/22 1 of 12. PageID #: 96 

DECLARATION OF BRIAN FEENEY 

PURSUANT TO 28 U.S.C. § 1746 

1. My name is Brian Feeney. I am over 18 years of age and live in Ohio. 

2. I have personal knowledge of the facts stated in this declaration, and if called as a 

witness, I could and would competently testify to the facts stated herein. 

3. I first talked to Adam Harmon about his mask business in December 2020. I had been 

fired from my previous job and was looking for work; I grew up down the street from Mr. 

Harmon and heard he had started a mask factory. 

4. Despite some legal troubles I was dealing with from my previous job, Mr. Harmon hired 

me. I started sitting in on meetings via phone in December 2020, and then started 

working for him fulltime at ALG Health in Bryan, Ohio in January 2021. 

5. Mr. Harmon hired me to run his sales team and be the National Sales Manager, but when 

I started working onsite, I found out some other guy already had the title of VP of Sales 

and Distribution. It was a little strange because the way it worked out, the “VP of Sales”

reported to me, the National Sales Manager. I ended up taking the title of VP of Sales & 

Marketing because a VP would not typically report to a National Sales Manager. 

6. At the first virtual meeting I attended in December 2020, red flags went up for me right 

off the bat. During that meeting, there was some big dilemma with ALG Health staff that 

involved a discussion about how many masks they could make every day. Some people 

said they could make 30,000 and some said 1,500. I was wondering, how could they be 

so far off on this? Don’t they need to know how many masks they can make in order to 

sell the masks profitably? But nobody had a good answer for me. 

7. When I started, one of my goals was to figure out how much it cost the company to make 

masks in order to make sure the company was profiting. 

Feeney Declaration Page 1 of 7 

Exhibit N 

p. 1 of 12
 

 

 

Case: 3:22-cv-01389 Doc #: 1-15 Filed: 08/05/22 2 of 12. PageID #: 97 

8. All the customers I spoke with would all have the same questions: How many masks do 

you have in inventory? How many masks can you make a day? How many will you be 

able to make a day in the near future? But I couldn’t get clear answers to any of those 

questions. 

9. I asked Jake Frederick, who handled shipping and had a background in procurement, for 

the bills of materials (BOMs) so I could see what was being purchased, coming in, and 

made. He just laughed, and said, “That’s the million-dollar question.” He told me things 

just showed up in trucks from Mr. Harmon’s buddy, James.

10. Exhibit A, attached hereto, is a sampling of commercial invoices that I received from Mr. 

Frederick and reviewed during my employment at ALG. These invoices show sales of 

“masks” and/or “mask material” from what I believed to be James’s companies, Venas 

Co., Ltd. and All Masks Co., Ltd. in Hong Kong, to ALG. 

11. Nobody really knows who James is; Mr. Harmon told me James is his best friend. I think 

Mr. Harmon met James through his lighting business; James loaned Mr. Harmon money 

and helped him get his business started. As of mid-late February 2021, I heard Mr. 

Harmon owed James $1.5 million. I told Mr. Harmon we needed to pay off James and 

sever the relationship. 

12. It was a strange situation; James was providing materials to us, but then we were 

competing against James. I had a call with a customer where I was trying to do volumebased discounts for $1.50 a mask, but the customer asked why they should buy from me 

when EPC was selling the same masks for $1. I found out later EPC was James! 

13. At one point I had a customer who wanted to place a bulk order for masks with numbers 

ending in 06 and 06s (for “small”), and I didn’t see anyone making those masks in the 

Feeney Declaration Page 2 of 7 

Exhibit N 

p. 2 of 12
 

 

Case: 3:22-cv-01389 Doc #: 1-15 Filed: 08/05/22 3 of 12. PageID #: 98 

back. I asked Mr. Harmon what the deal was, and he told me people overseas are making 

those masks for us according to our specifications. 

14. That didn’t sound too unusual to me; I am familiar with private label products based on 

my previous experience at a paint company, but I was concerned because I didn’t see

enough inventory to fulfill the order. 

15. Soon after, I walked into the back and saw what was likely hundreds of thousands of 

completed 06 and s06 masks there that weren’t in our facility the day before.

16. Mr. Frederick told me those were the “pre-mades.”

17. Exhibit B, attached hereto, is a sample of an inventory spreadsheet I received and 

reviewed during my employment at ALG. When you see a part number that starts with 

PA-, that “PA” stands for pre-assembled, meaning the masks arrived at the ALG facility 

complete, but had to have NIOSH markings printed on them. We were told that even 

though they were being made overseas, ALG had approval to do this because the “PA”

masks or “pre-mades” were produced to ALG specifications.

18. The premade masks showed up complete, with no markings, in bags packed inside boxes. 

Then, ALG employees printed NIOSH markings, part numbers, and labels on them inhouse, before boxing them in ALG packaging that said, “Made in USA.”

19. When customers asked, I told them those masks were made to our specifications outside 

the USA. Sometimes customers decided not to buy them because they preferred masks 

made in the USA. 

20. After observing the bags of premade masks in the clear bags, I made a list of concerns 

and asked to talk to Mr. Harmon. He was always hard to pin down for difficult 

conversations, but I went to his office and asked him why if masks could be made in 

Feeney Declaration Page 3 of 7 

Exhibit N 

p. 3 of 12
 

 

Case: 3:22-cv-01389 Doc #: 1-15 Filed: 08/05/22 4 of 12. PageID #: 99 

China for us, and they are made in China, we put them in boxes that said “Made in 

USA.” I also asked why the website said they were “Made in USA” and Berry 

Amendment-compliant. I was trying to understand because what we had didn’t seem to 

qualify for either of those statements. 

21. Mr. Harmon responded that I was right, and he should probably change some things. So, 

he changed some parts of the website to “Made in USA with globally sourced materials” 

and removed some of the Berry Amendment-compliant statements. 

22. In early-mid March 2021, I sat in on a call with NIOSH that made me nervous. NIOSH 

started the call with a fraud disclaimer, and then went on to tell us they received a report 

that someone received a box of our masks packed in a competitor’s box.

23. After the call, Mr. Harmon said it was no big deal. We didn’t talk too much right after 

the call because we had a group of people from “Ohio Means Jobs” meeting us at the 

facility. 

24. After the Ohio Means Jobs group left, we had a meeting in the conference room at the 

plant. Mr. Harmon disappeared for a bit, and then came back with a letter on 

CDC/NIOSH letterhead that he showed to me and Chad Hutson. The letter said ALGHealth was approved to have masks made for ALG in China. 

25. Something wasn’t right with the NIOSH letter. Mr. Hutson pointed out to me that it 

referred to “masks,” but NIOSH would have used the term “respirator.”

26. At one point, Chad Hutson called and asked me what I knew about KN95s being in the 

factory because he saw pallets and pallets of completed masks in KN95 boxes in the 

Bryan facility. 

Feeney Declaration Page 4 of 7 

Exhibit N 

p. 4 of 12
 

 

Case: 3:22-cv-01389 Doc #: 1-15 Filed: 08/05/22 5 of 12. PageID #: 100 

27. To my knowledge, we didn’t make KN95s. I saw the KN95 boxes labeled with Venas 

Company markings, and they looked like pretty legitimate Chinese masks. It was almost 

like Mr. Harmon got lazy; that day he just had the masks shipped in their boxes instead of 

pulling them out and putting them in unmarked bags like I had seen before. 

28. If I had to guess, I would say probably 80% or so of the masks we sold were imported 

masks. Maybe 20% of the masks ALG sold were made in Ohio; all the materials used to 

make those masks were imported. 

29. I noticed that the Ohio operation was very manual, and our production times were slow. 

Making masks in the Bryan facility was a laborious process. 

30. I estimate that ALG sold approximately 3-4 million masks. I couldn’t tell you what the 

profits were. At one point I said to Mr. Harmon, “you’ve been doing this a year and still 

don’t know how much it costs to make a mask!” It was impossible to get information out

of him because he was always hiding things. 

31. Mr. Harmon usually didn’t have end-of-month or sales recap meetings like other 

businesses had. 

32. I think ALG used an accounting firm, and that most of ALG’s sales records are in 

Quickbooks. Mr. Harmon also used another guy who also grew up down the street from 

us, Eric Rittenour, as a manufacturing accountant on an ad hoc basis. 

33. The first week of May 2021, Mr. Harmon laid everyone off. At that time, some of the 

NIOSH stuff going on was making me uncomfortable, so I decided to take a leave of 

absence to consider my next steps. I took two weeks off. Then, Mr. Harmon asked me to 

come back and said he would start to do things the “right way.”

Feeney Declaration Page 5 of 7 

Exhibit N 

p. 5 of 12
Case: 3:22-cv-01389 Doc #: 1-15 Filed: 08/05/22 6 of 12. PageID #: 101 

34. I returned to work in mid-May 2021, but by early August, another truckload of imported 

Chinese masks showed up. I had a problem with it. 

35. In August 2021, NIOSH asked us to stop selling respirators. NIOSH told Mr. Harmon to 

put a letter about the stop-sale on his website and he did, in a spot where it wasn’t very 

noticeable. 

36. Despite the August 2021 NIOSH stop-sale, Mr. Harmon continued to sell respirators with 

NIOSH markings. Instead of running the sales through the ALG Quickbooks account, he 

ran them through the Quickbooks account for his LED company, Axis LED Group. Mr. 

Harmon said this was okay because Axis was a distributor for ALG. I told him that was 

wrong. Mr. Harmon responded that we had to get rid of the inventory. Around this time, 

he cut me out of the loop on conversations with NIOSH. 

37. In September 2021, Burt Morlock and Chad Hutson got fired. In October, I told Mr. 

Harmon I needed a one-week vacation. I quit on October 12, 2021. 

38. ALG was Mr. Harmon’s company and he made the decisions regarding purchasing of 

materials and what products would be available to sell. We could have done things the 

right way without Mr. Harmon. The imported masks were actually pretty good masks 

and tested at over 95% filtration rates. They just weren’t made in Ohio. 

39. When I resigned and left, I told Mr. Harmon 100% of what he does is wrong; he just 

can’t do things the right way. It is unethical how he operates as a businessman, and I was 

not comfortable with what was going on. 

Feeney Declaration Page 6 of 7 

Exhibit N 

p. 6 of 12
_____________________________________ 

Case: 3:22-cv-01389 Doc #: 1-15 Filed: 08/05/22 7 of 12. PageID #: 102 

40. If anyone asks me why I quit working for ALG, it’s because I was asked to do something 

I thought was unethical. 

I declare under penalty of perjury that the foregoing is true and correct. 

Executed on February 16, 2022. 

Brian Feeney 

Feeney Declaration Page 7 of 7 

Exhibit N 

p. 7 of 12
Case: 3:22-cv-01389 Doc #: 1-15 Filed: 08/05/22 8 of 12. PageID #: 103 

All Masks Co.,Limited Commercial Invoice

FLAT/ROOM 1101D, 11/F, LIPPO SUN PLAZA, 28 CANTON ROAD, TSIM SHA TSUI,

PO. Number Trade Terms Payment Terms Via SHIP FROM

Net 90 Days PICK UP USA Warehouse

QTY(pcs) Model # Description Price Each (USD) Amount (USD)

216,000 Foldable mask Foldable mask 0.7 151,200.00

153,600 Big cup mask Big cup mask 0.8 122,880.00

Total 274,080.00

Payments/Credits

Balance Due

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

KOWLOON, HONGKONG

Bill To

1,AXIS LED GROUP, LLC

2106 Baltimore St Defiance,OH 43512

843-694-6469 adam@patriotled com

2,ALG HEALTH, LLC/ALG Manufacturing, LLC

520 W Mulberry ST Bryan, OH 43506/2106 Baltimore Defiance, OH 43512

843-694-6469 adam@alg-health com

ACCOUNT NAME: ALL MASKS CO., LIMITED

ACCOUNT NUMBER:

BANK NAME: HSBC Hong Kong

SWIFT CODE: HSBCHKHHHKH

BANK ADDRESS: 1 Queen's Road Central, Hong Kong

Date Invoice #

2021-3-22 AM-2021032201

Ship to

ALG HEALTH, LLC/AXIS LED GROUP, LLC

520 W Mulberry St Bryan, OH 43506

Atten: BURT MORLOCK

Email/Tel: 419-576-6950

CONFIRMED & ACCEPTED BY: AUTHORIZED SIGNATURE:

Signature of Seller: Signature of Buyer:

Feeney Exhibit A 

p. 1 of 4

Exhibit N 

p. 8 of 12
Case: 3:22-cv-01389 Doc #: 1-15 Filed: 08/05/22 9 of 12. PageID #: 104 

All Masks Co.,Limited Commercial Invoice

FLAT/ROOM 1101D, 11/F, LIPPO SUN PLAZA, 28 CANTON ROAD, TSIM SHA TSUI,

PO. Number Trade Terms Payment Terms Via SHIP FROM

Net 90 Days PICK UP USA Warehouse

QTY(pcs) Model # Description Price Each (USD) Amount (USD)

167,040 Small cup mask Small cup mask 0.8 133,632.00 

Total 133,632.00

Payments/Credits

Balance Due

Feeney Exhibit A 

p. 2 of 4

Exhibit N 

p. 9 of 12

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

-

KOWLOON, HONGKONG

Bill To

1,AXIS LED GROUP, LLC

2106 Baltimore St.Defiance,OH 43512

843-694-6469 adam@patriotled.com

2,ALG HEALTH, LLC/ALG Manufacturing, LLC

520 W Mulberry ST Bryan, OH 43506/2106 Baltimore Defiance, OH 43512

843-694-6469 adam@alg-health.com

Date Invoice #

2021-3-23 AM-2021032301

Ship to

ALG HEALTH, LLC/AXIS LED GROUP, LLC

520 W Mulberry St Bryan, OH 43506

Atten: BURT MORLOCK

Email/Tel: 419-576-6950

ACCOUNT NAME: ALL MASKS CO., LIMITED

ACCOUNT NUMBER:

BANK NAME: HSBC Hong Kong 

SWIFT CODE: HSBCHKHHHKH

BANK ADDRESS: 1 Queen's Road Central, Hong Kong

CONFIRMED & ACCEPTED BY: AUTHORIZED SIGNATURE:

Signature of Seller: Signature of Buyer:
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

\fNAS~ 

Case: 3:22-cv-01389 Doc #: 1-15 Filed: 08/05/22 10 of 12. PageID #: 105 

Venas Co.,Limited

FLAT/ROOM 1101D, 11/F, LIPPO SUN PLAZA, 28 CANTON ROAD, TSIM SHA TSUI, KOWLOON, HONGKONG

Bill To*:

Company name: AXIS LED GROUP, LLC

2953 N HONORE STREET CHICAGO, IL

Address: 60657/2106 Baltimore

St.Defiance,OH 43512

Attn: 843-694-6469

Email/Tel: ADAM@PATRIOTLED.COM

COMMERCIAL INVOICE

Ship To:

Company name: 

ALG HEALTH, LLC

Address: 520 W Mulberry St Bryan, OH

43506

Attn: BURT MORLOCK

Email/Tel: 419-576-6950

PO#: N/A

Item Model

1 Materials of 513 mask

2 Materials of 513S mask

3 Materials of 514 mask

TOTAL

Specification

Materials of 513 mask

Materials of 513S mask

Materials of 514 mask

PLEASE SEND US A COPY OF THE BANK SLIP AFTER PAYMENTS IS MADE

BANK INFORMATION

BENEFICIARY BANK: HSBC Hong Kong

ACCOUNT NO

SWIFT CODE: HSBCHKHHHKH

BENEFICIARY NAME: Venas Co.,Limited

BANK ADDRESS: 1 Queen's Road Central, Hong Kong

AUTHORIZED SIGNATURE : AUTHORIZED SIGNATURE:

Signature of Seller: Signature of Buyer:

Bill To*:

Company name: 

Address: 

Attn: 

Email/Tel:

Date:

PI#

Trade Terms

Payment Terms

Shipping

Location:

Ship Via

Shipment Date:

Quantity

(pcs)

42,240

30,720

67,000

139,960

ALG HEALTH, LLC/ALG Manufacturing,

LLC

520 W Mulberry ST Bryan, OH

43506/2106 Baltimore Defiance, OH

43512

843-694-6469

adam@alg-health.com

2021-3-23

ALG-0323-1

180DAY NET

Los Angeles Warehouse

PICK UP

Immediately

Unit Price Total

(USD) Amount (USD)

0.90 38,016.00

0.90 27,648.00

0.90 60,300.00

125,964.00

Feeney Exhibit A 

p. 3 of 4

Exhibit N 

p. 10 of 12
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

\fNAS~ 

Case: 3:22-cv-01389 Doc #: 1-15 Filed: 08/05/22 11 of 12. PageID #: 106 

Venas Co.,Limited

FLAT/ROOM 1101D, 11/F, LIPPO SUN PLAZA, 28 CANTON ROAD, TSIM SHA TSUI, KOWLOON, HONGKONG

Bill To*:

Company name: AXIS LED GROUP, LLC

2953 N HONORE STREET CHICAGO, IL

Address: 60657/2106 Baltimore

St.Defiance,OH 43512

Attn: 843-694-6469

Email/Tel: ADAM@PATRIOTLED.COM

COMMERCIAL INVOICE

Ship To:

Company name: 

ALG HEALTH, LLC

Address: 520 W Mulberry St Bryan, OH

43506

Attn: BURT MORLOCK

Email/Tel: 419-576-6950

PO#: N/A

Item Model

1 Materials of 521 mask

2 Materials of 511S mask

3 Materials of 513 test mask

4 Materials of 513S test mask

TOTAL

Specification

Materials of 521 mask

Materials of 511S mask

Materials of 513 test mask

Materials of 513S test mask

PLEASE SEND US A COPY OF THE BANK SLIP AFTER PAYMENTS IS MADE

BANK INFORMATION

BENEFICIARY BANK: HSBC Hong Kong

ACCOUNT NO:

SWIFT CODE: HSBCHKHHHKH

BENEFICIARY NAME: Venas Co.,Limited

BANK ADDRESS: 1 Queen's Road Central, Hong Kong

AUTHORIZED SIGNATURE : AUTHORIZED SIGNATURE:

Signature of Seller: Signature of Buyer:

Bill To*:

Company name: 

Address: 

Attn: 

Email/Tel:

Date:

PI#

Trade Terms

Payment Terms

Shipping

Location:

Ship Via

Shipment Date:

Quantity

(pcs)

700

800

500

500

2,500

ALG HEALTH, LLC/ALG Manufacturing,

LLC

520 W Mulberry ST Bryan, OH

43506/2106 Baltimore Defiance, OH

43512

843-694-6469

adam@alg-health.com

2021-3-23

ALG-0323-2

180DAY NET

Los Angeles Warehouse

PICK UP

Immediately

Unit Price Total

(USD) Amount (USD)

0.70 490 00

0.80 640 00

0.90 450 00

0.90 450 00

 2,030.00

Feeney Exhibit A 

p. 4 of 4

Exhibit N 

p. 11 of 12
L 

N95C-02 

N95C-02s 

N95C-02 PA 

(FMN511) 

N95CS-02 

N95CS-02s 

N95F-01 

N95F-01s 

N95F-01 PA 

(FMN521) 

N95C-06 

N95C-06PA 

(FMN513) 

N95CS-06 

N95CS-06PA 

(FMN513s) 

N95CV-03 

N95CVS-03 

Orders to Ship 

3/18/2021 within Next week 

129,000 

35,500 

101,600 

171,000* 

71,500 

24,000 

5,000 

63,600** 

3,000 

300 

52000 

52000 

20000 

Feeney Exhibit B 

ExhibitN 

p. 12 of 12 

Case: 3:22-cv-01389 Doc #: 1-15 Filed: 08/05/22 12 of 12. PageID #: 107 
	

 	 
 	 


 	 

	


 
  
 	
 
 	 




 	 	
 	
 
 		
 	 

 	  
 	 	

   
 
 	
 	
 
  	 
 	
 	 
 	 	
 	 
 		 

 	
  


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Case: 3:22-cv-01389 Doc #: 1-17 Filed: 08/05/22 1 of 2. PageID #: 109 

NIOSH Respiratory Protective Device Information 

NIOSH CA 2022-1042 

January 2022 

Effective Immediately: Voluntary Rescission of ALG Health Approvals 

Exhibit P 

p. 1 of 2
 

 

 

 

 

 

Case: 3:22-cv-01389 Doc #: 1-17 Filed: 08/05/22 2 of 2. PageID #: 110 

Effective Immediately: Voluntary Rescission of ALG Health Approvals 

The National Institute for Occupational Safety and Health (NIOSH) has honored a request by ALG 

Health to voluntarily rescind ALL NIOSH respirator approvals issued to ALG Health. The 13 rescinded 

approval numbers are provided below. 

As of January 6, 2022, any respirator marked with a NIOSH approval label indicating any of the 

approval numbers below is no longer NIOSH-approved. The NIOSH Certified Equipment List will no 

longer include these approval numbers. 

TC-84A-9259, TC-84A -9262, TC-84A-9270, TC-84A-9271, TC-84A-9273, TC-84A-9274, TC-84A-9275, 

TC-84A-9280, TC-84A-9281, TC-84A-9282, TC- 84A-9288, TC-84A-9290, and TC-84A-9292 

Due to the voluntary rescission of these NIOSH approvals, respirators bearing any of the NIOSH 

approval numbers listed above may no longer be manufactured, assembled, sold, or distributed. 

Please reach out to ALG Health for additional details related to their decision to voluntarily rescind the 

approvals identified in this notice. The Certified Equipment List can be used to locate other NIOSH 

approved respirators. 

Exhibit P 

p. 2 of 2
Case: 3:22-cv-01389 Doc #: 1-18 Filed: 08/05/22 1 of 1. PageID #: 111 

Exhibit Q
2/3/22, 1 : 1 0 PM ALG Health (@alghealth) • lnstagram photos and videos 

Q Search 

alqhealth I Follow □ ... 30 posts 42 followers 60following 

ALG Health 

Medical Equipment Manufacturer 

We manufacture NIOSH & FDA-certified masks right here in Ohio. We offer multiple varieties of N95 masks for 

retail and wholesale. 

www.alg-health.com 

1111 POSTS @ VIDEOS 

lappy 

Thanksgiving 

I 

_,,.,,. I 

From ALG Health / /)_,,.,,. 

Wishing everyone a day filled j / 

IC1'1e, laug: ter and lasting mem ✓ ,,, ) _,,.,,. ~ 

Our online 

store is open! 

stockmedicalsupply.com/ shop 

A LG 

https://www.instagram.com/alghealthnhl=en 

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® TAGGED 

Support US Manufacturers 

Buy Domesticolly-Mode PPE 

A.LG + 

---- MADE IN U SA ----

:tATRI07 

-IVIASKExhibitR 

p. 1 of 3 

1/3 

Case: 3:22-cv-01389 Doc #: 1-19 Filed: 08/05/22 1 of 3. PageID #: 112 
2/3/22, 1 : 1 0 PM ALG Health (@alghealth) • lnstagram photos and videos 

Q Search 

------·-----~-..-...---·---....... ---------------------- Look for these items printed 

on the mask: 

• Brand name 

• NIOSH-approved 

• Testing code & certification 

• Model number 

A LG 

A..\IMA ,WO$Cnts cho26$~blAll'lffl: ~~nuf;tct\lr~ ~ans·wercd Amenc.'$ 

C81fo,~PPC(l.rinoth$0ft5et olth8C:0Vl().19~, 

• 

https://www.instagram.com/alghealthnhl=en 

QUANTITY DISCOUNTS 

AVAILALBE 

Get o Quote 4 19.990.62 75 

A..LG Hec::h+ OT .,..,~r--.!!:' ,c .. ,.t1>,.a;;o""~ 0o,,,_,, 

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2/3 

ExhibitR 

p. 2 of 3 

Case: 3:22-cv-01389 Doc #: 1-19 Filed: 08/05/22 2 of 3. PageID #: 113 
2/3/22, 1:10 PM ALG Health (@alghealth) • lnstagram photos and videos 

Q Search Ciil V ffi 0 0 

Meta About Blog Jobs Help API Privacy Terms Top Accounts Hashtags Locations lnstagram Lite 

English v © 2022 lnstagram from Meta 

https://www.instagram.com/alghealth/?hl=en 

ExhibitR 

p. 3 of 3 

3/3 

Case: 3:22-cv-01389 Doc #: 1-19 Filed: 08/05/22 3 of 3. PageID #: 114 
LG Health 

INDUSTRIAL/ NON-SURCICAL 

"MOLDEDH N95 RESPIRATOR 

Part Number: PT-N95C/CS-02 

Description: Molded N95 rated 

respirator with nylon head 

bands 

KEY FEATURES: 

• ~95% BFE (Bacterial Rltration Efficiency) 

according to ASTM F2101 

• ~95% Filter Efficiency according to ICS 

Laboratories Inc. 

• Pre-formed for secure fit 

• Nosefoam 

• Moldable nose clip will help provide custom 

fit and secure seal. 

• Stapled headbands 

• Available in Small and Regular 

• Latex free: Yes 

• Model: Molded Cup 

DO NOT USE: 

• For atmospheres less than 19.5% oxygen 

• For gases and Vapors. including oil aerosols. etc. 

• If modified or used for its unintended purpose 

• Expiration date of 3 years after manufacture date 

Location: Manufactured in 

Ohio. USA 

Brand: Patriot Mask 

MATERIAL COMPOSITION: 

• Outer Layer: Spun bound cloth/non-woven 

fabric. 

• Straps - Polyisoprene 

• Staples - Ultrasonically welded 

• Nose Clip - Aluminum 

• Filter - Polypropylene 

• Shell - Polyester 

• Inner Layer: Needle punch cotton 

• Nose Clip: l mm Thick Metal 

• Nose Foam: Spandex filament sponge bar 

• Headband: Nylon string 

• Breathing valve: N/A 

DO USE FOR: 

• Medical clinics and operating rooms 

• Laboratory procedures 

• Infection control requirements 

• Emergency planning and preparedness 

..I 

3 

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(I) 

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Exhibit S 

p. 1 of 2 

Case: 3:22-cv-01389 Doc #: 1-20 Filed: 08/05/22 1 of 2. PageID #: 115 
LG Health 

INDUSTRIAL/ NON-SURCICA.L 

"MOLDEDH N95 RESPIRATOR Part Number: PT-N9SC/CS-02 

Description: Molded N95 rated 

respirator w ith nylon head 

bands 

NIOSH Industrial Rated Approved 

TC-84A-9259 {Regular}, TC-84A-9270 {Small} 

PACKACE INFORMATION 

Description 

PT-N95C-02 

PT-N95CS-02 

DIMENSIONS 

REGULAR 

PCS/Box 

25 

25 

Bo>r/Carton 

20 

20 

I ----- I I.. - - -.142mm - - .J 

Pcs/Pkg 

500 

500 

Location: Manufactured in 

Ohio. USA 

Brand: Patriot Mask ..I 

3 

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carton/Pallet Total Quan z 

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30 

30 

SMALL 

15,000 

15,000 

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Exhibit S 

p. 2 of 2 

Case: 3:22-cv-01389 Doc #: 1-20 Filed: 08/05/22 2 of 2. PageID #: 116