The U.S. Environmental Protection Agency, Region 9 (EPA), and OnTel Products Corporation ( Respondent ) agree to settle this matter and consent to the entry of this Consent Agreement and Final Order ( CAFO ), which simultaneously commences and concludes this matter in accordance with 40 C.F.R. Sections 22.13 and 22.18. Respondent agrees to the assessment of a penalty in the amount of $638,624 as final settlement of the civil claims against Respondent arising under the Act as alleged in Section I.C of the CAFO. Respondent certifies that, to the best of its knowledge, it is currently in compliance with any and all FIFRA requirements that apply to its ongoing operations.