1. surfactants, methylene chloride, trichloroethylene and 1,1,1-trichloroethane

29. At all relevant times, Defendant EASTMAN KODAK's products were sold to IBM and used by IBM employees, including plaintiffs and plaintiffs' decedent, causing them to suffer injurious exposure; these products include, but are not limited to, solvents and specialty chemicals.

30. At all relevant times, Defendant SHELL OIL COMPANY's products were sold to IBM and used by IBM employees, including plaintiffs and plaintiffs' decedent, causing them to suffer injurious exposure; these products include, but are not limited to, epoxy resins including EPON resins, organic solvents, including xylene, methylene chloride, trichloroethylene and 1,1,1-trichloroethane, and mineral oils.

31. At all relevant times, Defendant SHIPLEY COMPANY, INC.'s products were sold to IBM and used by IBM employees, including plaintiffs and plaintiffs' decedent, causing them to suffer injurious exposure; these products include, but are not limited to, photo resist and photo resist developer.

32. At all relevant times, Defendants SIGMA-ALDRICH CORPORATION, SIGMA ALDRICH, INC. dba SIGMA-ALDRICH SALES, INC. and SIGMA-ALDRICH COMPANY's products were sold to IBM, and used by IBM employees, including plaintiffs and plaintiffs' decedent, causing them to suffer injurious exposure; these products include, but are not limited to, chromium 1,1,1-trichloroethane ethylene dichloride, methylene chloride, trichloroethylene, 1,1,1-trichloroethane chromic anhydride dimethylsulfoxides, 1,4-dioxane: hexafluorobenzene phenol and potassium dichromate.

33. At all relevant times, Defendant UNION CARBIDE CORPORATION's products were sold to IBM, and used by IBM employees, including plaintiffs and plaintiffs' decedent, causing them to suffer injurious exposure; these products include, but are not limited to, solvents including, but not limited to, acetone, isophorone and glycol ether solvents, methylene chloride, trichloroethylene and 1,1,1-trichloroethane, and surfactants.

34. At all relevant times, Defendant E.I. DU PONT DE NEMOURS AND COMPANY's products were sold to IBM, and used by IBM employees, including plaintiffs and plaintiffs' decedent, causing them to suffer injurious exposure; these products include, but are not limited to, Frcon solvents.

35. At all relevant times, Defendant FISHER SCIENTIFIC COMPANY's products were sold Page 7

COMPLAINT FOR DAMAGES, PERSONAL INJURY AND WRONGFUL DEATH

MM 006958