**Document Content:**

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**Misrepresentations, Blanket Denials, Cover-ups and Obfuscation Communicated to IBM**

The document discusses misrepresentations, blanket denials, cover-ups, and obfuscation communicated to IBM for intended and expected repetition and/or communication by IBM to its workers, including Plaintiffs and Plaintiffs' decedent. These communications were made to keep plaintiffs and other IBM workers ignorant of the real association between exposure to chemicals in the clean rooms and chronic, irreversible disease and early death.

**Chemical Supplier Defendants**

90. Chemical Supplier Defendants made all the aforementioned misrepresentations to defendant IBM, fully anticipating, and intending that representatives of IBM would communicate repeat and/or convey such misinformation to its workers. In doing so, Defendant Suppliers intended to influence the behavior of IBM clean room workers. Defendant Suppliers further knew that as the intermediary, IBM, through whom their hazard communications would likely pass, would compound Defendants' miscommunications by conveying misleading information to its employees, thus extending and perpetuating a massive failure to provide full, accurate, and reliable information to Plaintiffs and Plaintiffs' decedent. Despite such knowledge, defendant Suppliers failed to ensure full and accurate information reached the intended recipients and instead allowed specific misrepresentations to be perpetuated and repeated as is more fully set forth below.

**Fraudulent Misrepresentations Regarding Specific So-Called "High Purity" Solvents Sold for Use in Manufacturing in IBM Disk Drive Coating and Related Electronic Device Production**

91. Xylene. At all times relevant, defendant Chemical Suppliers, including without limitation, Shell Oil Company and Hoechst Celanese Corporation, have known that the organic solvents they sold to IBM for use in disk drive coatings and related electronic devices manufacture not only produce a vapor that can ignite in the presence of heat, a spark or flame but that these vapors are extremely toxic to exposed persons. Defendant suppliers knew that the concentration of xylene vapor in air which must be reached for it to ignite is 10,000 ppm, that a warning light system tied to the risk of spontaneous ignition of xylene vapor should in fact be interpreted as a sign of extreme overexposure to a toxic vapor, that adverse health effects have been associated with exposure to xylene at concentrations well under the PEL and well under the OSHA permissible exposure limit [hereinafter "PEL"]. 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

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**COMPLAINT FOR DAMAGES, PERSONAL INJURY AND WRONGFUL DEATH!**

**MM 006974**