APR 2 2000 5:15 PM FR INNES DAY
2:3 243 2599 7:15:3#8:9:4288;22 = .45
04/10/00 16:21 FAX

Chemicals sector are and at all relevant times have been fully apprised of the fact that when it has sold and sells its so-called "ultra-high purity chemicals" to IBM, said highly toxic chemicals would be used in conjunction with numerous other highly toxic and hazardous chemicals in so-called "clean rooms" and that the Baker chemicals would contribute to the overall toxic exposure suffered by Plaintiffs, and other IBM workers, in this industrial chemical environment.

129. Defendant EM Industries, Inc., maintains and operates EM Science. EM Science publicly states that it is a "strong partner to the scientific community" which is a "leader in the scientific community, assisting chemists and laboratories with products and services for chemicals analysis and research and development work." EM Science also advertises that they offer "up-to-date information about applications and techniques for using EM Science products and on-line customer support." EM Science also operates the Chemicals for Optics and Electronics Group, which makes specialty chemicals for high tech industries, stating, "We are committed to providing high purity chemicals for application that fit your requirements for your most demanding application." Defendant EM Industries, Inc., and EM Science at all relevant times, through consulting and monitoring their chemicals performance, has been fully apprised of the fact that when it has sold and sells its so-called "ultra-high purity chemicals" to IBM, it has sold and is selling highly toxic chemicals which would be used in conjunction with numerous other highly toxic and hazardous chemicals in so-called "clean rooms" and that said chemicals would contribute to the overall toxic exposure suffered by Plaintiffs, and other IBM workers, in this industrial chemical environment.

130. Defendant Eastman Kodak publicly states that its Specialty Products, a division of "Kodak Professional" business unit, provides chemicals for printed circuit board fabrication and strives to be the "Recognized premier global provider of specialized imaging materials and solution to industry". Defendant Eastman Kodak at all relevant times, through consulting and monitoring their chemicals performance, has been fully apprised of the fact that when it has sold and sells its so-called "ultra-high purity chemicals" to IBM, it has sold and is selling highly toxic chemicals which would be used in conjunction with numerous other highly toxic and hazardous chemicals in so-called "clean rooms" and that said chemicals would contribute to the overall toxic exposure suffered by Plaintiffs, and other IBM workers, in this industrial chemical environment.
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COMPLAINT FOR DAMAGES, PERSONAL INJURY AND WRONGFUL DEATH
MM 006992