THIS COMPLAINT INCLUDES THREE COUNTS. THE FIRST TWO COUNTS ARE AGAINST SANDOZ AGRO, INC. AND SHIRLO, INC. RESPONDENT SANDOZ AGRO, INC. (SUBREGISTRANT) MADE CLAIMS IN ITS ADVERTISING MATERIALS FOR TWO PESTICIDE PRODUCTS THAT DIFFER SUBSTANTIALLY FROM CLAIMS MADE AS PART OF THE RGISTRATION STATEMENT SUBMITTED TO U.S. EPA. RESPONDENT SHIRLO, IS THE REGISTRANT FOR THESE TWO PESTICIDES. THE THIRD COUNT IS AGAINST SANDOZ AGRO, INC. ONLY FOR SALE/DISTRIBUTION OF AN UNREGISTERED PESTICIDE PRODUCT.