COMPLAINT FILED 9/30/99 PROPOSING A PENALTY OF $174,350. COMPLAINT ALLEGES: COUNTS I-VIII RESPONDENT DISTRIBUTED OR SOLD AN UNREGISTERED PESTICIDE, THE HEALTHY HUMIDIFIER PLUS . IN VIOLATION OF FIFRA SECTION 12(A)(1)(A). COUNTS IX-XVI RESPONDENT DISTRIBUTED OR SOLD A PESTICIDE WHICH WAS MIS- BRANDED. IN VIOLATION OF FIFRA SECTION 12(A)(1)(E). COUNTS XVII-XXX RESPONDENT DISTRIBUTED OR SOLD HEPATECH 375 PURIFICATION SYSTEM , WHICH WAS MISBRANDED. IN VIOLATION OF FIFRA SECTIO 12(A)(1)(F). COUNTS XXXI-XL RESPONDENT DISTRIBUTED OR SOLD HEPATECH 110 PURIFICATION SYSTEM , WHICH WAS MISBRANDED AT THE TIME OF INSPECTION. IN VIOLATION OF FIFRA SECTION 12(A)(1)(F). COUNTS XLI-XLIX RESPONDENT DISTRIBUTED OR SOLD A MISBRANDED PESTICIDE, HEPATECH 65 AIR PURIFICATION SYSTEM. IN VIOLATION OF FIFRA SECTION 12(A)(1)(F). COUNT L RESPONDENT WAS NOT A REGISTERED ESTABLISHMENT AS A PRODUCER. IN VIOLATION OF FIFRA SECTION 12(A)(2)(L). CACO ISSUED 10/4/99 ASSESSING A PENA