**Document Title:**

Monitoring post-sale the use of "electronic grade," "high purity," and "semiconductor grade" chemicals to the electronics industry including IBM.

**Page 36**

1. Monitoring post-sale the use of "electronic grade," "high purity," and "semiconductor grade" chemicals to the electronics industry including IBM.
2. Defendants, and each of them, were the designers, manufacturers, distributors, suppliers, sellers and post-sale monitors of hazardous chemical products which Defendants, and each of them, knew by reason of their aggressive pursuit of these lucrative business opportunities were being supplied for their utility as constituents in clean room chemical mixtures and/or in conjunction with other hazardous materials in clean rooms.
3. Defendant Suppliers, and each of them, have maintained divisions or departments dedicated to electronics and microcircuit industry and have required the Defendant Suppliers to inspect, investigate and understand both "clean room" procedures and operating conditions. At all relevant times as a result of their post-sale monitoring and "trouble shooting" activities, the Defendant Suppliers have known that their products were used in electronics industry "clean rooms" in conjunction with other likewise toxic and hazardous compounds and materials, that the "clean room" air circulation systems were designed only to remove particulates and that such systems actually re-circulate and re-distribute volatile toxic substances throughout the "clean room" air.
4. The chemical supplier Defendants, including Defendant Fisher Scientific Company, have also maintained divisions or departments or subsidiaries dedicated to the design, manufacture and marketing and post-sale monitoring of the performance of personal protective equipment for chemical handlers, and therefore have another basis from which to have known of the conditions in "clean rooms" in the electronics industry and the hazards inherent in them.
5. At all relevant times, Defendant E. I. DuPont de Nemours and Company has operated and maintained a Microcircuit Materials Division with a stand-alone Electronics Materials Headquarters now located in Research Triangle Park, North Carolina, a hub for technological and toxicological research. DuPont actively markets its expertise in chemical compounds, materials and mixtures for the microcircuitry industry. As of 1997, DuPont was publicly advertising to the world that DuPont has had over 30 years' experience in post-sale monitoring and troubleshooting on products it provides to the electronics industry, including IBM. At all relevant times, Defendant DuPont has known as a result of its post-sale monitoring and trouble shooting activities that when it has sold and sells its epoxy resins

**Complaint for Damages, Personal Injury and Wrongful Death**

MM 006987