those Plaintiffs, who are not currently employed by IBM, and who were exposed to such chemicals designed, manufactured, sold, distributed, produced or introduced in the stream of commerce by IBM as a product for commercial use, make direct claims against IBM.

28. At all relevant times, the defendants negligently failed to design said chemicals to ensure they were not carcinogenic, teratogenic, developmentally toxic or otherwise injurious to the health and safety of those employed in the semiconductor manufacturing process, or to their offspring.

29. At all relevant times, the defendants negligently failed to manufacture said chemicals to ensure they were not carcinogenic, teratogenic, developmentally toxic or otherwise injurious to the health and safety of those employed in the semiconductor manufacturing process, or to their offspring.

30. At all relevant times, the defendants negligently failed to test said chemicals to determine whether they were carcinogenic, teratogenic, developmentally toxic or otherwise injurious to the health and safety of those employed in the semiconductor manufacturing process, or to their offspring.

31. At all relevant times, the defendants negligently failed to warn of the dangers associated with exposure to said chemicals.

32. At all relevant times, the defendants negligently