# INTERNATIONAL BUSINESS MACHINES CORPORATION (hereinafter "IBM") was authorized to do business in the State of New York.

22. At various times between 1964 and 1996, the Plaintiffs and/or Plaintiffs' decedents, other than infant Plaintiffs, were employed in certain buildings at IBM plants where semiconductor "wafers", "chips" and/or "boards" were being manufactured and assembled for use in computers.

23. Each of the defendants designed, manufactured, sold, distributed, supplied, and/or installed chemicals, that were utilized in IBM plants in the manufacturing process of said semiconductor computer "wafers", "chips", and/or "boards".

24. Said defendants provided training, instructions and warnings for the use of said chemicals to said IBM plant management, personnel and contractors.

25. The Plaintiffs' and Plaintiffs' decedents' employment on or about the assembly line of said semiconductor "wafers", "chips" and/or "boards" resulted in prolonged contact and exposure to said chemicals.

26. One or both of the parents of each infant Plaintiff was exposed to said chemicals prior to and/or subsequent to the conception of each infant Plaintiff and each infant Plaintiff was thus exposed to and harmed by said chemicals prior to birth as a result of their parent's or parents' exposure.

27. The Plaintiffs decedents and Plaintiffs, and only

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IBM-ZRIND 64220