disk drive coatings were developed, had developed terminal cancers, particularly of the brain (John Wong and Al Smith), lymphatic and hematopoietic systems (Gordon Moi and Dwayne Johnson), and gastrointestinal system (Robert Cappell and Ken Hart).

77. The false representations to Plaintiffs and Plaintiffs' decedents reported above have been made even though IBM knew, based on IBM's internal Corporate Mortality File, a database with work history information on over 10,000 deceased IBM workers, that at least 149 long-term IBM workers had died of primary brain cancer between 1975 and 1989, and that ten years or more in engineering and technical work, i.e. manufacturing, at IBM was a significant risk factor for primary brain cancer. IBM has also known that the risk of primary brain cancer is increased ten fold in workers with 20 or more years employment in electronics manufacturing and repair, where there was exposure to toxic chemicals.

These false representations to IBM employees were made with malice and with the intent of concealing from workers IBM's knowledge that exposure to chemicals in manufacturing put them at significantly increased risk of cancer, particularly brain cancer. Non-Hodgkins' lymphoma, gastric cancers and leukemia.

78. False representations to Plaintiffs and Plaintiffs' decedent reported above have been made repeatedly by IBM to Customer Service Department Managers for dissemination to Customer Service Department workers, even though IBM has known since 1980 of the terminal cancers of two young employees, Lucy Vargas Kneebone and Frank Olson, both of whom had extensive exposure to trinitrofluorenone prior to their onset of their terminal cancers.

79. Defendant IBM has concealed medical information from Plaintiffs, Plaintiffs' decedent, and their authorized representatives, despite repeated formal requests for this information. Plaintiffs and Plaintiffs' decedent are, and at all relevant times have been, plainly and fully entitled to this information under 320S of the General Industrial Safety Orders of the State of California, as well as federal OSHA disclosure requirements of which IBM has had notice since before 1976. This pattern and practice of willfully and intentionally withholding pertinent exposure, medical records, and documents concerning toxic chemicals to which Plaintiffs and Plaintiffs' decedent have been exposed occurred during Plaintiffs' employment, during the period following their departure from IBM and during the pendency of the instant litigation.