**APP 12 2000 5:16 PM FR JONES DAY**
**04/10-00 12:22 FAX**

**industrial chemical environment.**

137. Defendant Electronic Materials, Inc. maintains an Electronics Products Division, which designs, develops, manufactures and markets microchip bonders, electrically conductive coatings, surface mount adhesives, thermally conductive coatings, conformal coatings, and chip on boards at all relevant times. Chemical engineers from Electronic Materials have made site visits to IBM "clean rooms" to provide on-site consultations with IBM managers regarding the performance of "clean room" chemicals. At all relevant times Defendant Electronic Materials has known that when it sold its electronics products to IBM, it sold 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 Electronic Materials' chemicals would contribute to the overall toxic exposure suffered by Plaintiffs, and other IBM workers, in this industrial chemical environments.

138. Defendant Epoxylite Corp. maintains an Electronics Products Division, which designs, develops, manufactures and markets microchip bonders, electrically conductive coatings, surface mount adhesives, thermally conductive coatings, conformal coatings, and chip on boards. It publicizes its expertise. At all relevant times, chemical engineers from Epoxylite have made site visits to IBM "clean rooms" to provide on-site consultations with IBM managers regarding the performance of "clean room" chemicals. At all relevant times Defendant Epoxylite has known that when it has sold and sells its electronics products 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 Epoxylite chemicals would contribute to the overall toxic exposure suffered by Plaintiffs, and other IBM workers, in this industrial chemical environment.

139. As a result of their aggressive post-sale pursuit and implementation of these mutually lucrative business partnerships with the electronics industry, including IBM, Defendants, and each of them, knew and consciously promoted as their role in the partnership the facilitation of the exposure of IBM employees, including Plaintiffs and Plaintiffs' decedent, to an abnormally dangerous and ultra-hazardous environment and Defendants thus were active post-sale business partners with IBM in an abnormally dangerous and ultrahazardous activity.

140. As a result of their successful post-sale pursuit and implementation of these lucrative Page 44

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

MM 006995