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01/10/00 12:17 FAX

market.

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.

High Technology Bonding Agents, Surfactants and Adhesives

104. Defendants Conap, Inc., Loctite Corp., The Dexter Corp., Electronic Materials, Inc., Eastman Kodak and Devcon-Plexus all represented to IBM and through IBM to its employees including plaintiffs, in Material Safety Data Sheets and other product literature that their adhesive products were high quality and could be used safely by workers in the electronics industry. These representations were made repeatedly even though these adhesive manufacturers had never tested their products as mixtures to ascertain their carcinogenicity, mutagenicity, or endocrine disruption ability. These representations were also made even though the basis for many of these adhesives has been a resin made from epichlorohydrin and bisphenol A. Epichlorohydrin has been suspected to be a carcinogen since the mid 1970s. The endocrine-disrupting ability of bisphenol A was reported since 1934. 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 Plaintiffs and Plaintiffs' decedent. Plaintiffs detrimentally relied upon those misrepresentations and omissions made to IBM and repeated, communicated and/or in some fashion authoritatively conveyed to them.

105. These grossly misleading representations about product safety, made to induce electronics industry customers to purchase and use these products without questioning if these products will put their employees at risk, have been made for the express purpose of material gain at the expense of persons who derive no benefit whatsoever from their use of and exposure to these materials.

106. The true and full measure of this protracted deception worked on electronics industry workers by these defendants has not been fully uncovered by plaintiffs and their representatives for the reason that these defendants persist in covering up the hazards of their products and for the additional Page 22

COMPLAINT FOR DAMAGES, PERSONAL INJURY AND WRONGFUL DEATH

MM 006983