**APR 12 2000 5:15 PM FR JONES DAY**
**2:3 243 2539 TO 15:3#818:4238:20 = .44**
**04/10/00 12:20 FAX **

1 Carbide has known as a result of these post-sale monitoring and consulting that when it has sold and is selling its so-called "ultra-high purity chemicals" to IBM, said highly toxic chemicals would be used in conjunction with numerous other highly toxic and hazardous chemicals in so-called "clean rooms" and that the Union Carbide chemicals would contribute to the overall toxic exposure suffered by Plaintiffs and other IBM workers, in this industrial chemical environment.
2 At all relevant times, chemical engineers from Defendant Hoechst Celanese have made post-sale site visits to IBM electronics manufacturing "clean rooms" to provide on-site consultations with IBM managers regarding the performance of "clean room" chemicals.
3 At all relevant times Defendant Hoechst Celanese has known as a result of its post-sale consulting and monitoring that when it has sold and sells its so-called "ultra-high purity chemicals" to IBM, said highly toxic chemicals which would be used in conjunction with numerous other highly toxic and hazardous chemicals in so-called "clean rooms" and that the Hoechst Celanese chemicals would contribute to the overall toxic exposure suffered by Plaintiffs, and other IBM workers, in this industrial chemical environment.
4 Defendant J.T. Baker, Inc., k/n/a Mallinckrodt Baker, Inc. reports to the world that the J.T. Baker brand is "America's most trusted name in laboratory chemicals" whose axiom is "that those who purchase chemicals have a need to know the purity of what they buy." J.T. Baker today characterizes itself as a "worldwide producer of ... microelectronic chemicals," "the leader in wafer cleaning technologies" and "a leading manufacturer of acids, solvents, and etchants for the semiconductor industry." (Semiconductor Supersite.Net). J.T. Baker reports that:
5 J.T. Baker microelectronic chemicals are used extensively by worldwide producers of semiconductor chips ... product line ... which includes a broad range of traditional cleaning products, particulate specified process chemicals, photo resist strippers, ash residue removers, etching chemicals and other more specialized products. As with all J.T. Baker products, microelectronic chemicals are produced in ISO-certified facilities and are backed by in-depth chemical service.
6 At all relevant times chemical engineers and representatives from J.T. Baker, including J. D. Harper, Christopher Lapsey and Sara Fineman, have made post-sale site visits to IBM electronics manufacturing "clean rooms" to provide on-site consultations with IBM employees regarding the performance of "clean room" chemicals. By its own conduct, by its own acknowledgment, by reason of these post-sale consultations and monitoring, Defendant Mallinckrodt Baker, Inc., and its J.T. Baker Microelectronic Page 40
7 COMPLAINT FOR DAMAGES, PERSONAL INJURY AND WRONGFUL DEATH
MM 006991