APP 12 2000 5:15 PM FR 'ONES DAY 213 243 2538 ** 15:3#6:3:4258:22 = .47
04/19/00 12:21 FAX

sells its so-called "ultra-high purity chemicals" to IBM, said highly toxic chemicals which would be used
in conjunction with numerous other highly toxic and hazardous chemicals in so-called "clean rooms"
and that the Conap chemicals would contribute to the overall toxic exposure suffered by Plaintiffs, and
other IBM workers, in this industrial chemical environment.

135. Defendant Loctite Corp. maintains an Electronics Products Division which designs,
develops, manufactures and markets microchip bonders, electrically conductive coatings, surface mount
adhesives, thermally conductive coatings, conformal coatings, and chip on boards. At all relevant times
chemical engineers from Loctite have made site visits to IBM "clean rooms" to provide on-site post-sale
consultations with IBM managers regarding the performance of "clean room" chemicals. Of one dozen
Loctite customers identified on the Loctite home page, three are microelectronics and semiconductor
manufacturers: Texas Instruments, Siemens, and Motorola. Loctite further promotes its expertise in
serving the microelectronics industry by asserting: "Loctite's laboratories can simulate a customer's
production environment to test the user-friendly nature of our products." At all relevant times Defendant
Loctite has known as a result of its post-sale consults and monitoring that when it has sold and sells its
Electronics Products to IBM, said highly toxic chemicals which would be used in conjunction with
numerous other highly toxic and hazardous chemicals in so-called "clean rooms" and that the Loctite
chemicals would contribute to the overall toxic exposure suffered by Plaintiffs, and other IBM workers,
in this industrial chemical environment.

136. Defendant ITW, Inc., and Devcon-Plexus Corp. maintain an electronics products division,
known on information and belief as "Devcon Plexus" which division designs, develops, manufactures
and markets microchip bonders, electrically conductive coatings, surface mount adhesives, thermally
conductive coatings, conformal coatings, and chip on boards. It publicizes its expertise. At all relevant
times, chemical engineers from Devcon have made site visits to IBM "clean rooms" to provide on-site
consultations with IBM managers regarding performance of "clean room" chemicals. At all relevant
times Defendants ITW, Inc., and Devcon-Plexus Corp. has known that when it has sold and sells its
electronics products 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 Devcon chemicals
would contribute to the overall toxic exposure suffered by Plaintiffs, and other IBM workers, in this
Page 43

COMPLAINT FOR DAMAGES, PERSONAL INJURY AND WRONGFUL DEATH

MM 006994