**Bermuda Branch**
29 Richmond Road, Pembroke HM 08 Bermuda
P.O. Box HM 152, Hamilton HM AX, Bermuda
Telephone: (441) 293 - STAR (7827)
Facsimile: (441) 292 - 8093

**APR 19 2000**

**Via Facsimile and First Class Mail**

April 10, 2000

David Blake
Manager of Risk & Insurance Management
IBM
New Orchard Road
Armonk, NY 10504
U.S.A.

**Re:** Named Insured: International Business Machines Corporation
Following Form Excess Liability Insurance

**Matter:** (1) Clean Room Chemical Litigation
Notification of 9 lawsuits listing 237 plaintiffs
(2) John Cataldo, et al. v. Union Carbide Corporation, et al.
(3) Heather Kelly, et al. v. Union Carbide Corporation, et al.
(4) Doris Barbosa, et al. v. International Business Machines Corporation, et al.
(5) Thomas L. Furr v. Flour Daniels, Inc., et al.
(6) James Michael Abbaticchio v. Union Carbide Corporation, et al.
(7) Christina Cordaro v. International Business Machines, et al.
(8) John William Evans v. Union Carbide Corporation, et al.

Starr Policy No: 400001
Starr File No: (1) 98-400000-001

Dear Mr. Blake:

This will acknowledge receipt of notice of the captioned clean room chemical litigation.

Given Starr Excess International is a high-level follow form insurer, and only began providing coverage to IBM on May 21, 1998, I do not believe there is a need at this juncture for us to actively investigate these losses or analyze coverage. That being said, you should be aware that the nine suits referred to in your August 18, 1998 transmittal were all filed before the Starr Excess International policy's inception date, and indeed appear to have been previously notified to other insurance carriers. Moreover, the

Contd...

Starr Excess Liability Insurance International Limited
Incorporated in the Republic of Ireland
MM 002787