IN THE MATTER OF 

UNITED STATES OF AMERICA 

DEPARTMENT OF TRANSPORTATION 

OFFICE OF HEARINGS 

WASHINGTON, D.C. 

RECEIVED 

MAY 1 1 2015 

HEARING DOCKET 

IXL Premium Lubricants, Inc., 

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AMENDED ANSWER 

IXL Premium Lubricants, Inc. (IXL) answers as follows. 

1. IXL admits Section I of the Complaint. 

2. IXL admits paragraph ILl of the Complaint. 

FAA Case No. 2014NM720059 

Docket No. FAA-2015-0634 

Judge Richard C. Goodwin 

3. Answering paragraph II.2 of the Complaint, IXL denies its employees are inadequately 

or improperly trained, denies all other allegations, and affirmatively asserts based on information 

and belief that the Agency has mis-assessed the gas treatment. 

4. Answering paragraph II.3 of the Complaint, IXL denies it mislabeled the product, 

denies all other allegations, and affmnatively asserts based on information and belief that the 

Agency has mis-assessed the gas treatment. 

5. Answering paragraph II.4 of the Complaint, IXL denies it miscertified and misnoticed 

the product, denies all other allegations, and affirmatively asserts based on information and belief 

that the Agency has mis-assessed the gas treatment. 
6. Answering paragraph II.5 of the Complaint, IXL denies it failed to adequately 

document the product, denies all other allegations, and affirmatively asserts based on information 

and belief that the Agency has mis-assessed the gas treatment. 

7. IXL admits paragraph II.6 of the Complaint. 

8. Answering paragraph II. 7 of the Complaint, IXL denies the product was improperly 

packed, denies all other allegations, and affirmatively asserts based on information and belief 

that the Agency has mis-assessed the gas treatment. 

9. Answering paragraph II.8 of the Complaint, IXL denies the product was improperly packed, 

denies all other allegations, and affirmatively asserts based on information and belief that the 

Agency has mis-assessed the gas treatment. 

10. Answering paragraph II.9 of the Complaint, IXL denies its employees are inadequately or 

improperly trained, denies all other allegations, and affirmatively asserts based on information 

and belief that the Agency has mis-assessed the gas treatment. 

ll. Answering paragraph ILl 0 of the Complaint, IXL denies its employees are inadequately or 

improperly trained, denies all other allegations, and affirmatively asserts based on information 

and belief that the Agency has mis-assessed the gas treatment. 

12. Answering paragraph III.l.a of the Complaint, this paragraph is a statement oflaw requiring 

no response. To the extent it requires a response, IXL denies all allegations and affirmatively 

asserts based on information and belief that the Agency has mis-assessed the gas treatment. 

l3. Answering paragraph III.l. b of the Complaint, this paragraph is a statement oflaw requiring 

no response. To the extent it requires a response, IXL denies all allegations and affirmatively 

asserts based on information and belief that the Agency has mis-assessed the gas treatment. 

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14. Answering paragraph III.l.c of the Complaint, this paragraph is a statement of law requiring 

no response. To the extent it requires a response, IXL denies all allegations and affirmatively 

asserts based on information and belief that the Agency has mis-assessed the gas treatment. 

15. Answering paragraph III.l.d of the Complaint, this paragraph is a statement oflaw requiring 

no response. To the extent it requires a response, IXL denies all allegations and affirmatively 

asse1is based on information and belief that the Agency has mis-assessed the gas treatment. 

16. Answering paragraph Ill.l.e of the Complaint, this paragraph is a statement oflaw requiring 

no response. To the extent it requires a response, IXL denies all allegations and affirmatively 

asserts based on information and belief that the Agency has mis-assessed the gas treatment. 

17. Answering paragraph III.l.f of the Complaint, this paragraph is a statement of law requiring 

no response. To the extent it requires a response, IXL denies all allegations and affirmatively 

asserts based on information and belief that the Agency has mis-assessed the gas treatment. 

18. Answering paragraph Ill.l.g of the Complaint, this paragraph is a statement of law requiring 

no response. To the extent it requires a response, IXL denies all allegations and affirmatively 

asserts based on information and belief that the Agency has mis-assessed the gas treatment. 

19. Answering paragraph JII.l.h of the Complaint, this paragraph is a statement of law requiring 

no response. To the extent it requires a response, IXL denies all allegations and affirmatively 

asserts based on information and belief that the Agency has mis-assessed the gas treatment. 

20. Answering paragraph III.l.i of the Complaint, this paragraph is a statement of law requiring 

no response. To the extent it requires a response, IXL denies all allegations and affirmatively 

asserts based on information and belief that the Agency has mis-assessed the gas treatment. 

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21. Answering paragraph III.2 of the Complaint, this paragraph is a statement of law requiring no 

response. To the extent it requires a response, IXL denies all allegations and affirmatively asserts 

based on information and belief that the Agency has mis-assessed the gas treatment. 

22. IXL denies paragraph III.3 of the Complaint. 

23. IXL denies all allegations of the Complaint not expressly admitted. 

,, DATED: April ~''\ , 2015 

Jordan Olsen 

Head of Operations, IXL 

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