**Draft**

April 21, 2000

Mr. David A. Balmuth  
Senior Vice President-Legal Claims  
STARR Excess International  
29 Richmond Road, Pembroke HM 08 Bermuda  
P.O. Box HM 152  
Hamilton HM AX Bermuda  

Re: Insured: International Business Machines Corporation  
Excess Liability Insurance  
Starr Policy No.: 400001  
Effective: May 21, 1998  
Starr File No.: 98-400000-001  

1) Clean Room Litigation  
Notification of 9 Lawsuits (237 Plaintiffs)  

2) John Cataldo, et al  

3) Heather Kelly, et al  

4) Doris Barbosa, et al  

5) Thomas L. Furr  

6) James M. Abbaticchio  

7) Christina Cordaro  

8) John W. Evans  

Dear Mr. Balmuth:

Thank you for your letter of April 10, 2000. Please be advised that Mr. David Blake is no longer with our Corporation. Regarding item number one in the caption of your letter, we inadvertently notified your company of the nine cases in our letter of August 18, 1998. It appears that the Complaints indicate that they were filed prior to the inception of the Starr policy. We apologize for any inconvenience to you.

As for the balance of the claims referenced in your letter of April 10th, a perusal of the Complaints show they contain common allegations to all causes of actions that, "At all times between 1964 and the present", (ie date of filing of the Complaints), the employees/plaintiffs worked in "clean rooms" and were allegedly exposed to certain chemicals. The Complaints do not list dates of employment or dates of alleged exposure, or when plaintiffs medical conditions were diagnosed. Therefore, in an abundance of caution, IBM's insurers were notified from the earliest time frame referenced, up through the date of filing of the Complaints, which included notification to your company whose coverage became effective May 21, 1998.

Very truly yours,

Mark Dupuy

MM 002784