10. The representations that their electronics sector products are safe have been perpetuated even though epidemiologists and researchers with Union Carbide Corp., Shell Oil Company, E. I. DuPont de Nemours and Company, Shipley Company, Inc., Hoechst Celanese Corp., J.T. Baker, Inc. k/n/a Mallinckrodt Baker, Inc., Fisher Scientific Company and the trade associations to which these defendants have belonged have known since at least 1987 that the risk of brain cancer is increased ten fold in workers with 20 years of employment or greater in electronics manufacturing and repair where there is exposure to solvents, solder fumes, and other chemicals.

11. Defendant: E. I. DuPont de Nemours and Company, represented in all of its Material Safety Data Sheets provided to IBM for dissemination to IBM workers, including plaintiffs, that the DuPont products provided to IBM San Jose, including various "Freon" solvents, were free of adverse health effects and did not contribute to any increase in cancer risk. These representations have been made even though DuPont has known that female chemical workers employed by DuPont have had a significantly increased incidence of breast cancer, that other industrial workers exposed to Freon have had significantly elevated rates of breast cancer, and that DuPont's male employees have had significantly elevated rates of melanoma and intestinal cancers. Notwithstanding such knowledge, these suppliers conveyed grossly misleading and inadequate information to IBM regarding these dangers, knowing and intending that IBM would repeat, convey or in some fashion communicate these misleading statements to its employees, including Plaintiff and Plaintiffs' decedent who detrimentally relied upon these misrepresentations and omissions made to IBM and repeated, communicated and/or in some fashion authoritatively conveyed to them.

12. Throughout the 1980s, Defendant: Union Carbide Corp., represented in all of its Material Safety Data Sheets provided to IBM for dissemination to IBM workers, including plaintiffs, that the products provided to IBM San Jose including organic solvents and particularly including isopropyl alcohol were free of adverse health effects and did not contribute to any increase in cancer risk when Union Carbide knew that Union Carbide's chemical workers had a significantly increased incidence of pancreatic cancer and that this cancer was strongly associated with exposure to organic solvents; Union Carbide also knew that women workers with industrial exposure to isopropyl alcohol have been reported to be at significantly increased risk for breast cancer. Notwithstanding such knowledge, these suppliers

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COMPLAINT FOR DAMAGES, PERSONAL INJURY AND WRONGFUL DEATH
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This text appears to be part of a legal document, specifically a complaint for damages related to personal injury and wrongful death. It details allegations against several companies (Union Carbide Corp., Shell Oil Company, E.I. DuPont de Nemours and Company, etc.) regarding the safety of their products and the misrepresentation of health risks to IBM workers, including plaintiffs.