THIS CASE IS BEING BROUGHT AGAINST PK ELECTORNICS, INC. FOR VIOLATIING SECTION 103 OF THE MERCURY CONTAINING AND RECHARGEABLE BATTERY MANAGEMENT ACT (MRBMA). THIS IS A COMPLAINT AND SETTLEMENT FOR THE LABELLING AND EASY REMOVABLITY PARTS OF SECTION 103. THE COMPLAINT IS SEEKING INJUCTIVE RELIEF TO REMEDY THE VIOLATIONS. IN PARTICULAR, ADVISING PAST AND PRESENT CUSTOMERS ON BATTERY REMOVABLE, TERMS OF MRBMA, AND REVISING PRODUCT LITERATURE ANDPOSITING INFOMATION ABOUT THEMRBMA ON THEIR WEBSITE.