**August 30, 1996**

**Mr. Herbert Mitchell**
Claims Coordinator
**LIBERTY MUTUAL**
1133 Sixth Avenue
New York, New York 10036

**INTERNATIONAL BUSINESS MACHINES CORPORATION**
**RUFFING, ET AL VS. UNION CARBIDE CORPORATION, ET AL**

Dear Mr. Mitchell:

Enclosed is a copy of a summons & complaint served upon International Business Machines Corporation in connection with the captioned litigation.

The complaint alleges that plaintiffs were harmed as a result of prolonged contact and exposure to harmful chemicals while employed in certain buildings at IBM plants where semiconductor products were being manufactured and assembled for use in computers. In the case of the infant plaintiffs it is alleged that they were injured as a result of their parent's prolonged contact and exposure to chemicals prior to their birth.

The complaint does not specifically outline the relationship between plaintiffs and International Business Machines Corporation and consequently this matter is being reported to Zurich-American and American International Group who provided General Liability coverage to International Business Machines Corporation between 1964 and 1996 which is the alleged exposure period.

International Business Machines Corporation has arranged for the Jones, Day lawfirm to protect their interests. The following attorneys from Jones, Day are leading the defense effort.

Michael Templeton, Esq.
Jones, Day
599 Lexington Avenue
New York, New York 10022
Tel. No.: 212-326-3485

IBM-ZRIND 64176