OPINION OF THE COURT
SLOVITER, Circuit Judge.
The petitioner, Sultan Chemists, Inc. ("Sultan"), has filed a petition for review of the final decision of the Environmental Appeals Board ("EAB") of the Environmental Protection Agency ("EPA"). The EAB affirmed an administrative enforcement action against Sultan for eighty-nine violations of § 12 of the Federal Insecticide, Fungicide, and Rodenticide Act ("FIFRA"), 7 U.S.C. § 136j (2001),
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