On October 13, 2005, the Chief Counsel issued an Order to Pinnacle Products, Inc., (Respondent) finding the Respondent had knowingly committed six violations of the Hazardous Materials Regulations (HMR), and assessing a civil penalty in the amount of $13,995. The Chief Counsel granted a ten percent (10%) reduction for the packaging violation and a fifteen percent (15%) reduction for the shipping name violation, stating Respondent's evidence of corrective action did not fully address the violations. The Chief Counsel granted a twenty-five percent (25%) reduction for the security plan and registration and closure violations. Respondent did not submit any additional evidence of corrective action for consideration with its appeal. Respondent did not submit any financial information for consideration by the Chief Counsel. Respondent did not submit any new information with its appeal to substantiate its claims of financial hardship. Although Respondent states it is no longer operating, it has maintained its incorporation in the State of Texas and has not dissolved its assets. Respondent's appeal is denied.