**August 30, 1996**

**Mr. Joseph Combader**
Claims Manager
**AIG CLAIMS SERVICE**
Two Jericho Plaza
Jericho, New York 11753

**INTERNATIONAL BUSINESS MACHINES CORPORATION**
**RUFFING, ET AL VS. UNION CARBIDE CORPORATION, ET AL**

Dear Mr. Combader:

Enclosed is a copy of a summons and complaint served upon IBM in connection with the captioned matter.

The complaint alleges that plaintiffs were harmed as a result of prolonged contact and exposure to harmful chemicals while employed in certain buildings at IBM plants where semiconductor products were being manufactured and assembled for use in computers. In the case of the infants plaintiffs it is alleged that the parent's of these plaintiffs were in prolonged contact and exposure to harmful chemicals prior to the infant plaintiffs birth.

In view of the fact that the complaint does not indicate the precise relationship between the plaintiffs and International Business Machines Corporation this matter has been reported to the Zurich-American Insurance Group who provided Comprehensive General Liability coverage for International Business Machines Corporation prior to the effective date of the first American International Group Policy which became effective on 1/1/95 and Liberty Mutual Insurance Company who provided Employers Liability coverage for International Business Machines Corporation during the alleged exposure period of 1964 to 1996. Enclosed are copies of my notifications to these carriers.

International Business Machines Corporation has retained the Jones, Day lawfirm to protect their interests. The following attorneys from Jones, Day are leading the defense effort:

IBM-ZRIND 64178