Industrial Heat and IPH (collectively “Counter-Plaintiffs”) bring this action against Leonardo; Rossi; J.M. Products, Inc. (“JMP”); Henry Johnson (“Johnson”); Penon; United States Quantum Leap, LLC (“USQL”); and Fabiani.
Industrial Heat LLC has brought counterclaims against almost everyone involved in the Rossi project and makes allegations of fraud in the performance, review and testing of the E-cat.

Eventually Counter-Plaintiffs discovered that the test that Leonardo and Rossi were conducting, in conjunction with the supposed “customer” in Miami, was not a real test at all, but a carefully scripted effort to deceive Counter-Plaintiffs into 1) providing Leonardo and Rossi with credibility in their efforts to license and promote the E-Cat IP to others and/or obtain investments from others in their business ventures, 2) making the third payment under the License Agreement to Leonardo, 3) paying a multitude of expenses of Leonardo and Rossi including in connection with their operations in Florida, and 4) paying Penon and Fabiani for services not rendered and reimbursing them for unnecessary expenses.

Answer and exhibits available here.