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January 16, 2026
Dear Sir or Madam:
Blank Rome LLP represents Ice Air, LLC in connection with this matter. We are aware that Ephoca Inc. has issued false and damaging statements about Ice Air, including that it “lies,” “cheats,” and makes “fraudulent claims” about its products. The statements are false, as Ephoca well knows, because they are contradicted by publicly accessible government filings confirming that Ice Air’s products are third-party tested and conform to regulatory standards.
Ice Air understands that Ephoca is concerned by its inability to fairly compete in the marketplace. Nevertheless, Ephoca’s attacks are an unlawful method of competition that have harmed Ice Air. By this letter, Ice Air demands that Ephoca cease and desist its unlawful conduct and issue a public apology retracting its false statements.
Ephoca has publicly made a series of false and defamatory statements about Ice Air and its products. The below is only a sample of Ephoca’s claims:
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“[Ice Air] cheats by publishing performance numbers that are not derived from any laboratory testing. Its ratings are fabricated, not measured, and therefore illegal.”
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“[Ice Air lacks] a valid AHRI heating certification, a valid NRTL heating test report, or any published numbers that match the OEM’s actual performance.”
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“None of Ice Air’s units appear in DOE’s CCMS database.”
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“None of Ice Air’s products has been tested in a real lab.”
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Ice Air “fails SEER2 minimums” and “fails HSPF2 minimums because numbers are fake.”
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“Ice Air’s 8RSSXC09-DH is illegal to distribute, specify, install, or use because it does not meet the DOE energy efficiency requirements for a heat pump.”
In a brazen attempt to intimidate Ice Air’s customers, Ephoca also insists that installing Ice Air’s products creates civil and criminal liability for engineers, installers, and building owners.
Ephoca’s accusations have been escalating, with false statements repeated on its official LinkedIn page and by its General Manager, Yehuda Fulda. Ice Air also understands that Ephoca, including its Vice President, Yohai West, is sponsoring multiple smear websites that repeat false claims that Ice Air’s capacity and claimed SEER2 values are fabricated, and again threaten Ice Air’s customers with criminal prosecution.
Ephoca’s attacks are false, as it knows. Ice Air’s products comply with federal and state law and are backed by third-party testing verifying published energy efficiency ratings. The iCool XC 8RSXC09-DH, the subject of Ephoca’s attacks:
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Is tested and certified by a U.S. Nationally Recognized Testing Laboratory
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Meets federal Department of Energy standards, including Appendix M1 to Subpart B of Part 430, Title 10 of the U.S. Code of Federal Regulations, incorporating the AHRI 210/240 standard
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Is listed in the U.S. Department of Energy CCMS database
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Meets California Energy Commission SEER2 and HSPF2 requirements
Because this information is publicly available, Ephoca knows its statements are false. Ephoca’s purpose in publishing this misinformation can only be to unlawfully harm a market rival. While Ephoca claims it has tested Ice Air’s units, it has published no test results. Ephoca’s statements amount to intimidation through false claims of criminal liability. Ice Air has already been harmed by these malicious statements and has lost business as a result of Ephoca repeating these falsehoods to customers.
Ephoca, Mr. West, and Mr. Fulda’s statements expose them to civil liability under state law defamation, commercial disparagement, unfair competition statutes, and the federal Lanham Act. Ephoca appears aware of this exposure, confirming the statements were made knowingly and willfully.
Ice Air demands that Ephoca and its officers, employees, and agents, including Mr. Fulda and Mr. West:
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Immediately remove all false public statements regarding Ice Air and its products
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Cease and desist from making any further false or defamatory statements
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Issue a public apology correcting its false statements
This letter also requires implementation of a litigation hold to preserve all documents, communications, records, and data from January 2023 to the present that relate to Ice Air or its products, including materials stored on personal devices.
Please respond no later than January 26, 2026 confirming compliance.
This letter does not constitute a complete statement of Ice Air’s rights, all of which are expressly reserved.
Very truly yours,