131. Defendant The Dexter Corporation maintains and operates Dexter Electronic Materials.
2 Dexter Electronic Materials publicly advertises that it is a "leading, broad-based, global manufacturer of specialty chemicals for the electronics industry." At all relevant times, chemical engineers from Dexter have made site visits to IBM "clean rooms" to provide on-site consultations with IBM managers regarding the performance of "clean room" chemicals. Dexter produces its electronic industry specialty products in its own "ISO9001 clean rooms" and knows that a particle-free "clean room" contains a multiplicity of toxic chemicals and vapors.

132. As a technology leader since 1948 Dexter produces state-of-the-art specialty materials from four United States ISO9001 registered manufacturing facilities. Dexter is a company producing specialty materials for customers in four strategic global markets: aerospace, electronics, food packaging and medical. Defendant Dexter Corporation 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.

133. Defendant Conap Inc., publicly characterizes itself via the Internet as follows: CONAP is partnered with leading companies in the aerospace, computer, defense, biomedical, electrical/electronics, automotive and other leading technologic manufacturers. CONAP's product promotional materials describe its product line as "high technology polyurethane and epoxy resin systems" and asserts that "(W)e are especially proud of the material contributions that our R & D efforts have made possible in assuring the successful operation of a number of advanced product systems, subsystems and devices currently in use in the electronics, defense, computer, automotive and biomedical fields."

134. At all relevant times, chemical engineers from Conan have made post-sale site visits to IBM electronics manufacturing "clean rooms" to provide on-site consultations with IBM managers regarding the performance of "clean room" chemicals. By its own conduct and as a result of these post-sale consults and monitoring, at all relevant times Defendant Conap has known that when it has sold and

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COMPLAINT FOR DAMAGES, PERSONAL INJURY AND WRONGFUL DEATH

MM 006993