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Document1 Filed 08/25/26 Page 1 of 69\n\nUNITED STATES DISTRICT COURT\nDISTRICT OF VERMONT\n\nLINDA ALLARD, CATHERINE BRYARS,\n\nSCOTT ELITHORPE, GALE ELMORE, Case No.: 2:26-cv-00291\nALFONSO GIORGI, NICOLE LEBERT,\n\nSHAWN LEGACY, and DEBORAH\n\nSWANSON,\nPlaintiffs,\nCOMPLAINT \u2014 CLASS\nVv. ACTION\nSAINT-GOBAIN PERFORMANCE PLASTICS DEMAND FOR JURY TRIAL\nCORPORATION,\n3M COMPANY,\n\nE.]. DUPONT DE NEMOURS AND\nCOMPANY, EIDP, INC., THE CHEMOURS\nCOMPANY, and CORTEVA, INC.,\n\nDefendants.\n\nPlaintiffs, individually and on behalf of the putative classes of similarly situated\npersons defined herein, file this Master Class Action Complaint and allege as follows:\n\nSTATEMENT OF THE CASE\n\n1. This is a Class action on behalf of Plaintiffs and Class of people similarly situated\nwho have been damaged and continue to be damaged by the wrongful conduct of Defendants Saint-\nGobain Performance Plastics Corporation (\u201cSGPP\u201d), 3M Company (\u201c3M\u201d), E.I. DuPont De\nNemours and Company, EIDP, Inc., The Chemours Company and Corteva, Inc., (all collectively\n\nreferred to as \u201cDuPont\u201d), arising out of Defendants\u2019 manufacture, distribution, sale, use, handling,\n\f2:26-cv-00291-kjd Document1 Filed 08/25/26 Page 2 of 69\n\nrelease, discharge and disposal of perfluorooctanoic acid (\"PFOA\")! and products releasing PFOA,\na known toxic, perfluorinated chemical, at manufacturing facilities located on Water Street in\nNorth Bennington and Northside Drive in Bennington, Vermont (the \u201cSGPP Facilities\u201d), which\nhas resulted in the severe contamination of the local groundwater aquifer, soils, and private\ndrinking water supply wells with PFOA in and around Shaftsbury and Bennington, Vermont. In\nparticular, for over 20 years, Defendant SGPP, and its predecessor in interest Chemfab\nCorporation (\u201cChemfab\u201d), utilized APFO and APFO-containing products, manufactured and sold\nby Defendants 3M and DuPont, in its manufacturing processes at the SGPP Facilities, and released\nsignificant amounts of PFOA into the environment through air emissions, as wel] as through\nvarious discharges to soils, sediments, and surface waters, thereby causing widespread\ngroundwater and property contamination. Plaintiffs and Class Members bring negligence,\nnuisance, and strict liability claims and statutory causes of action against Defendants due to the\ndiminution in property value, loss of use and enjoyment of property, annoyance, upset, aggravation\nand inconvenience and other damages which they have suffered as a result of the PFOA\ncontamination caused by Defendants. Plaintiffs and Class Members seek damages and/or equitable\nrelief pursuant to the Vermont Medical Monitoring Statute (12 V.S.A. \u00a7 7202). Plaintiffs and\nClass Members also seek damages and/or equitable relief for the unreasonable harm to\ngroundwater caused by Defendants in violation of the Vermont Groundwater Protection Act (10\nV.S.A. \u00a71410) as a result of this PFOA contamination, and also seek further equitable and\ninjunctive relief to compel Defendants to establish and implement remedial measures sufficient to\n\npermanently prevent the further contamination, and eliminate the current contamination, of\n\n1 \u201cDFOA\u201d is the acid form of ammonium perfluorooctanoate (\u201cAPFO\u201d). APFO is the ammonium salt form of the\nmolecule; it dissociates into PFOA in water and sublimes directly to PFOA vapor when heated. Both APFO and\nPFOA are frequently referred to as \u201cC-8\u201d because of the eight carbon structure of both molecules. In this complaint,\nAPFO, PFOA and C-8 will be used to describe the same chemical.\n\n2\n\f2:26-cv-00291-kjd Document1 Filed 08/25/26 Page 3 of 69\n\nPlaintiffs' and Class Members' properties and/or private drinking water supplies with PFOA.\n\nJURISDICTION AND VENUE\n\n2. Subject matter jurisdiction is proper in this Court pursuant to the Class Action\nFairness Act, 28 U.S.C. \u00a7 1332(d), because members of the proposed Plaintiff classes include\nnumerous citizens of the State of Vermont, and defendants are residents of different states, and the\nageregate amount in controversy exceeds $5,000,000, exclusive of interest and costs.\n\n3. Personal jurisdiction is proper over Defendants because they were authorized to do\nbusiness in Vermont, registered with the Vermont Secretary of State, transacting business with\nsufficient minimum contacts in Vermont, and/or otherwise intentionally availing themselves of the\nVermont market through manufacturing, marketing, distribution, and/or sale of PFAS-containing\nproducts in Vermont so as to satisfy minimum contacts and to render the exercise of jurisdiction\nover Defendants by Vermont courts consistent with traditional notions of fair play and substantial\njustice. Due to Defendants\u2019 tortious conduct, Plaintiffs have foreseeably suffered harm in the State\nof Vermont as set forth herein.\n\n4, Venue is proper in this Court pursuant to 28 U.S.C. \u00a7 1391(b), because thjs action\nconcerns damage to property located in this District, Defendants have conducted substantial\nbusiness in this District, Defendants have caused harm to Class Members residing in this District,\nPlaintiffs reside in this District, and a substantial part of the events or omissions giving rise to\nPlaintiffs\u2019 claims occurred in the District of Vermont.\n\nPARTIES\nPlaintiffs\n5. Plaintiff Linda Allard is a resident of the State of Vermont and Town of\n\nBennington, owning property located at 295 Hickory Hill Road, Bennington Vermont. Plaintiff\n\f2:26-cv-00291-kjd Document1 Filed 08/25/26 Page 4 of 69\n\nAllard has resided at such residence since 2003 and has continuously consumed drinking water\nfrom a private well that was found to be contaminated with PFOA at 52.55 parts per trillion (\u201cppt\u201d)\nby the Vermont Department of Environmental Conservation (\u201c\u201cWTDEC\u201d) on August 31, 2023. A\npoint of entry treatment system (\u201cPOET\u201d) was installed on such well in October of 2023 and is still\noperating to remove PFOA from her drinking water. Upon information and belief, Plaintiff Allard\nhas PFOA in her blood in excess of 2.00 parts per billion (\u201cppb\u201d) as a result of drinking\ncontaminated water from her well for over two decades. Upon information and belief, the soil on\nPlaintiff Allard\u2019s property is also contaminated with PFOA. Upon information and belief, the\nPFOA contamination of Plaintiff Allard\u2019s property has reduced the resale value of such property.\n\n6. Plaintiff Catherine Bryars is a resident of the State of Vermont, Town of\nBennington, co-owning property located at 212 Middle Pownal Road, in Bennington, Vermont\nsince 2017. Plaintiff Bryars has resided at such residence since 2017 and has continuously\nconsumed drinking water from a private well that was found to be contaminated with PFOA at\n33.1 ppt by VTDEC on October 30, 2023. A POET was installed on such well in 2024 and is still\noperating Jo remove PFOA from her drinking water. Upon information and belief, Plaintiff Bryars\nhas PFOA in her blood in excess of 2.00 ppb as a result of drinking contaminated water from her\nwell for seven years. Upon information and belief, the soil on Plaintiff Bryars\u2019 property is also\ncontaminated with PFOA. Upon information and belief, the PFOA contamination of Plaintiff\nBryars\u2019 property has reduced the resale value of such property.\n\n7. Plaintiff Scott Elithorpe is a resident of the State of Vermont, Town of Shaftsbury,\nowning property located at 279 Furnace Brook Road since 1999. His property is located in close\nproximity to wells that have already tested positive for PFOA contamination. Upon information\n\nand belief, Plaintiff Elithorpe\u2019s soil is contaminated with PFOA and as a result, his drinking water\n\f2:26-cv-00291-kjd Document1 Filed 08/25/26 Page 5 of 69\n\nwell is at risk of future PFOA contamination. Upon information and belief, the contamination on\nPlaintiff Elithorpe\u2019s property has reduced the resale value of such property.\n\n8. Plaintiff Gale Elmore is a resident of the State of Vermont, Town of Bennington,\nowning property located at 1089 Main Street. Plaintiff Elmore resided at the property from her\nbirth in 1955 until 2001, and again upon assuming ownership in 2012 to present. Her property is\nlocated in close proximity to wells that have already tested positive for PFOA contamination.\nUpon information and belief, Plaintiff Elmore\u2019s soil is contaminated with PFOA and as a result,\nher drinking water well is at risk of future PFOA contamination. Upon information and belief, the\ncontamination on Plaintiff Elmore\u2019s property has reduced the resale value of such property.\n\n9. Plaintiff Alfonso Giorgi is a resident of the State of Vermont, Town of Shaftsbury,\nco-owning property located at 72 Lucas Lane since 2009. Plaintiff Giorgi has resided at such\nresidence since 2009 and continuously consumed drinking water from a private well dug in 2010\nthat was found to be contaminated with PFOA at 33 ppt by VTDEC on December 12, 2023. A\nPOET was installed on such well in 2024 and is still operating to remove PFOA from his drinking\nwater. Upon information and belief, Plaintiff Giorgi has PFOA in his blood in excess of 2.00 ppb\nas a result of drinking contaminated water from his well for over fourteen years. Upon information\nand belief, the soil on Plaintiff Giorgi\u2019s property is also contaminated with PFOA. Upon\ninformation and belief, the PFOA contamination of Plaintiff Giorgi\u2019s property has reduced the\nresale value of such property.\n\n10. Plaintiff Nicole Lebert is a resident of the State of Vermont, Town of Bennington,\nowning property located at 17 Stonehedge Drive since 2019. Plaintiff Lebert has resided at such\nresidence since 2019 and continuously consumed drinking water from a private well that was\n\nfound to be contaminated with PFOA at 42.6 ppt on September 15, 2023. A POET was installed\n\f2:26-cv-00291-kjd Document1 Filed 08/25/26 Page 6 of 69\n\non such well in January of 2024 and is still operating to remove PFOA from her drinking water.\nUpon information and belief, Plaintiff Lebert has PFOA in her blood in excess of 2.00 ppb as a\nresult of drinking contaminated water from her well for over four years. Upon information and\nbelief, the soil on Plaintiff Lebert\u2019s property is also contaminated with PFOA. Upon information\nand belief, the PFOA contamination of Plaintiff Lebert\u2019s property has reduced the resale value of\nsuch property.\n\n11. Plaintiff Shawn Legacy is a resident of the State of Vermont, Town of Shaftsbury,\nco-owning property located at 76 Lucas Lane since 2001. Plaintiff Legacy has resided at such\nresidence since 2009 and continuously consumed drinking water from a private well dug in 2010\nthat was found to be contaminated with PFOA at 17 ppt by VTDEC on December 12, 2023. A\nPOET was installed on such well in January 2025 and is still operating to remove PFOA from his\ndrinking water. Upon information and belief, Plaintiff Legacy has PFOA in his blood in excess of\n2.00 ppb as a result of drinking contaminated water from his well for over twenty years. Upon\ninformation and belief, the soil on Plaintiff Legacy\u2019s property is also contaminated with PFOA.\nUpon information and belief, the PFOA contamination of Plaintiff Legacy\u2019s property has reduced\nthe resale value of such property.\n\n12. Plaintiff Deborah Swanson is a resident of the State of Vermont, Town of\nShaftsbury, co-owning property located at 257 Lower East Road since 1996. Plaintiff Swanson\nhas resided at such residence since 1996 and continuously consumed drinking water from a private\nwell installed in 2003 that was found to be contaminated with PFOA at 19.1 ppt by VIDEC on\nJanuary 24, 2024. A POET was installed on such well in June of 2025 and is still operating to\nremove PFOA from her drinking water. Upon information and belief, Plaintiff Swanson has\n\nPFOA in her blood in excess of 2.00 ppb as a result of drinking contaminated water from her well\n\f2:26-cv-00291-kjd Document1 Filed 08/25/26 Page 7 of 69\n\nfor over twenty years. Upon information and belief, the soil on Plaintiff Swanson\u2019s property is\nalso contaminated with PFOA. Upon information and belief, the PFOA contamination of Plaintiff\nSwanson\u2019s property has reduced the resale value of such property.\n\nDefendants\n\n13. Defendant SGPP is and was at all times relevant hereto a corporation organized\nunder the laws of California with its principal executive office located at 20 Moores Road,\nMalvern, Pennsylvania. SGPP is registered to do business as a foreign corporation in the State of\nVermont.\n\n14. SGPP\u2019s parent company global headquarters are located in Courbevoie, France, and\nit is a multi-national corporation with more than 350 years of engineered materials expertise. It is\none of the 100 largest industrial companies in the world with approximately $54 billion in sales in\n2025.\n\n15. | SGPP is the world\u2019s leading producer of engineered, high-performance polymer\nproducts, serving virtually every major industry across the globe.\n\n16. | SGPP and its predecessor Chemfab, at various times as set out in more detail\nherein, operated manufacturing facilities in North Bennington and Bennington, Vermont, including\nthe SGPP Facilities.\n\n17. The VTDEC identified Defendant SGPP as a party responsible for the PFOA\ncontamination in the local groundwater aquifer and numerous private drinking water supply wells\nin and around the Towns of Bennington and Shaftsbury, as a result of its operations at the SGPP\nFacilities.\n\n18. Defendant EIDP, Inc. (\u201cOld DuPont\u201d) is a foreign corporation authorized to do\n\nbusiness in the State of Vermont and, at all times relevant hereto, has conducted business in this\n\f2:26-cv-00291-kjd Document1 Filed 08/25/26 Page 8 of 69\n\nDistrict. E.I. du Pont de Nemours and Company changed its name to EIDP, Inc., in 2023. Among\nother acts and omissions, Defendant Old DuPont has for many years manufactured and supplied\naqueous fluoropolymer dispersions (AFD) using the tradename Teflon\u00ae containing APFO to\nSGPP and its predecessor corporation, Chemfab, that operated fabric coating facilities in North\nBennington, Vermont.\n\n19, Defendant The Chemours Company (\u201c\u201cChemours\u201d) is a foreign corporation\nauthorized to do business in the State of Vermont and, at all times relevant hereto, was conducting\nbusiness in this District. Among other acts and omissions, Defendant Chemours has assumed\nPFAS-related liabilities from Old DuPont.\n\n20. Defendant Corteva, Inc. (\u201cCorteva\u201d) is a foreign corporation authorized to do\nbusiness in the State of Vermont and, at all times relevant hereto, was conducting business in this\nDistrict. Among other acts and omissions, Defendant Corteva has assumed PFAS-related liabilities\nfrom Old DuPont.\n\n21. Defendant DuPont de Nemours, Inc. (\u201cNew DuPont\u201d) is a foreign corporation that\nconducts business in the State of Vermont and, at all times relevant hereto, was conducting\nbusiness in this District. Among other acts and omissions, Defendant New DuPont has assumed\nPFAS-related liabilities from Old DuPont.\n\n22. In 2015, Old DuPont spun off its performance chemicals business (which included\nthe design, manufacture, marketing, and sale of PFAS, as well as a substantial portion of Old\nDuPont\u2019s PFAS-related environmental liabilities) to Chemours.\n\n23. By 2013, Old DuPont understood that it faced massive, mounting environmental\nliabilities arising from its decades-long manufacture, use, marketing, sale, and distribution of\n\nPFAS, likely totaling in the billions of dollars.\n\f2:26-cv-00291-kjd Document1 Filed 08/25/26 Page 9 of 69\n\n24, Beginning in or around 2013, Old DuPont sought to isolate these PFAS-related\nliabilities from its billions of dollars in valuable assets and to evade responsibility for the\nenvironmental harms it caused. This scheme unfolded over several years and involved the creation\nof multiple new corporate entities.\n\n25. The first major step in this scheme was the 2015 spinoff of Chemours, a newly\nformed entity that received Old DuPont\u2019s Performance Chemicals business. Along with this\ntransfer, Old DuPont saddled Chemours with a significant portion of Old DuPont\u2019s environmental\nliabilities.\n\n26. Per the separation agreement between Old DuPont and Chemours, Chemours\nassumed liabilities related to Old DuPont\u2019s manufacture, use, and sale of PFAS and agreed to\nindemnify Old DuPont against all liabilities associated with the Performance Chemicals business\u2014\nregardless of when those liabilities arose and against whom those liabilities are asserted or\ndetermined.\n\n27. Internally, Old DuPont knew that Chemours lacked the financial resources to\nadequately cover the PFAS-related liabilities Old DuPont had transferred to Chemours.\n\n28. In 2017, Old DuPont completed a merger with The Dow Chemical Company (\u201cOld\nDow\u201d) to create DowDuPont, Inc. This so-called \u201cmerger of equals\u201d was carefully structured to\navoid exposing Old Dow\u2019s assets to Old DuPont\u2019s PFAS liabilities. Rather than a true integration,\nthis transaction served as a temporary restructuring vehicle by which Old DuPont sought to further\nseparate the company\u2019s valuable assets from its PFAS liabilities and other environmental\nobligations.\n\n29. Following the merger, assets were stripped out of Old DuPont and transferred to\n\nDowDuPont, which then mixed and combined the assets of Old DuPont with the assets of Old\n\f2:26-cv-00291-kjd Document1 Filed 08/25/26 Page 10 of 69\n\nDow. DowDuPont then organized its business into three distinct business segments: Agriculture,\nMaterials Science, and Specialty Products.\n\n30. This restructuring paved the way for the creation of three independent companies\nby 2019: (1) Corteva, which holds the Agriculture business and became the parent holding\ncompany of Old DuPont; (2) Dow, Inc. (\u2018New Dow\u201d), which holds the Materials Science business\nand became the parent company of Old Dow; and (3) DuPont de Nemours, Inc. (i.e., New\nDuPont), which was formerly known as DowDuPont and retained the Specialty Products business\nas well as some non-core business segments and product lines once belonging to Old DuPont.\n\n31. Pursuant to the separation agreement between Corteva, New Dow, and\nDowDuPont/New DuPont, Corteva and New DuPont have each assumed responsibility for certain\nOld DuPont liabilities, including Old DuPont liabilities related to PFAS.\n\n32. Further, to resolve a lawsuit, Chemours, Old DuPont, New DuPont, and Corteva\nagreed to accept responsibility for and to allocate liabilities related to PFAS.\n\n33. Defendant 3M is and was at all times relevant hereto a corporation organized under\nthe laws of Minnesota with its principal executive office located at 3M Center Building 220-9E-02,\nSaint Paul, Minnesota. 3M is registered to do business as a foreign corporation in the State of\nVermont. At all times relevant hereto, Defendant 3M conducted business in the State of Vermont.\nIt manufactured APFO, including its product FC-143, and sold its APFO containing products to\nDefendant SGPP and its predecessor Chemfab. These products were used as an additive to AFD in\nDefendant SGPP and Chemfab\u2019s manufacturing processes as described herein. In addition, 3M\nsold Chemfab FC-170C, which was a sulfonated perfluorochemical that can degrade into\nperfluorooctanesulfonate (PFOS).\n\n34. Defendant 3M manufactured and sold APFO to DuPont and other manufacturers\n\n10\n\f2:26-cv-00291-kjd Document1 Filed 08/25/26 Page 11 of 69\n\nfor production of AFD and other fluoropolymer products, including polytetrafluorethylene\n(\u201cPTFE\u201d) and fluorinated ethylene propylene (\u201cFEP\u201d)* dispersion products through approximately\n2002, and these AFD products were sold to defendant SGPP and its predecessor Chemfab and used\nat the SGPP Facilities in the manufacturing processes as described herein.\n\nGENERAL FACTUAL ALLEGATIONS\n\nBackground Regarding PFOA\n\n35. | Ammonium Perfluorooctanoate (\u201cAPFO\u201d) dissociates in water to form\nperfluorooctanoate (PFO-) and under acidic conditions is protonated to form perfluorooctanoic\nacid (\u201cPFOA\u201d).\n\n36. | Attemperatures over 150 \u00b0 C APFO sublimes (converts from solid form directly\ninto a gas) into PFOA vapor.\n\n37. PFOA isa fluorinated organic chemical that is part of a larger group of chemicals\nreferred to as perfluoroalkyl substances (\u201cPFAS\u201d) or perfluorochemical compounds (\u201cPFC\u201d) that\ninclude PFOS. .\n\n38. | PFOA and all PFCs are human-made chemicals that are not found in nature.\n\n39. | 3Mis the inventor and original manufacturer of APFO having begun manufacturing\nthe chemical in approximately 1947 at its Cottage Grove plant in Minnesota. It ceased selling\nAPFO in or about 2002.\n\n40. Defendant DuPont began manufacturing APFO after 3M chose to stop selling the\nchemical in 2002, and DuPont then continued to manufacture APFO and use it in its\n\nmanufacturing processes until approximately 2014.\n\n2 References to AFD are intended to also include PTFE, FEP and other APFO-containing\ndispersions manufactured by defendants DuPont and 3M.\n\n11\n\f2:26-cv-00291-kjd Document1 Filed 08/25/26 Page 12 of 69\n\n41. \u2014 Historically, APFO was used as a polymerization aid in manufacturing\nfluoropolymers and as a surfactant and wetting agent in AFD.\n\n42. PFOA is a white solid at ambient temperature, but sublimates to a vapor when\nheated during processing of AFD and during the manufacturing of PTFE fine powder. When\nAFD is heated to coat fabric and other substrates, PFOA vaporizes out of the AFD and is\nexhausted through stacks at manufacturing facilities. When PFOA cools, it condenses back into\nsolid form and, within minutes, it coagulates and forms micro-sized particulates ranging from\n0.1m to 1pm in diameter that are then carried by the wind until they settle to the ground (dry\ndeposition) or are washed from the atmosphere by precipitation (wet deposition). Because of its\nhigh solubility in water, when PFOA particulate matter settles into soil through dry or wet\ndeposition, it readily percolates down deeper to contaminate groundwater.\n\n43. Due to its chemical structure, PFOA is biologically and chemically stable in the\nenvironment and is strongly resistant to environmental degradation to the point of being virtually\nindestructible under environmental conditions. Thus, PFOA remains present in the environment\nindefinitely after it is initially released earning it the moniker \u201ca forever chemical\u201d. There is no\nknown environmental breakdown mechanism for PFOA. It is readily absorbed into biota and\naccumulates with repeated exposure.\n\n44. In 2006, the United States Environmental Protection Agency (\u201cEPA\u201d)\nimplemented a global stewardship program that included eight major perfluoroalky!\nmanufacturing companies, including Defendants DuPont and 3M. The stewardship program\u2019s\ngoal was to achieve a 95% reduction of global facility emissions of PFOA and chemicals that\ndegrade into PFOA by 2010, and eliminate PFOA from emissions and products by 2015.\n\nAccording to the EPA, all eight companies that participated in the program have attested that\n\n12\n\f2:26-cv-00291-kjd Document1 Filed 08/25/26 Page 13 of 69\n\nthey phased out PFOA, and chemicals that degrade to PFOA, from emissions and products by\nthe end of 2015.\nPFOA is a Toxic Chemical\n\n45. PFOA isa proven toxic substance as it is (i) listed on the EPA\u2019s Consolidated List\nof Chemicals subject to the Comprehensive Environmental Response, Compensation, and Liability\nAct, (ii) defined as a \u201chazardous material\u201d under 10 V.S.A. \u00a7 6602, (iii) testing has produced\nevidence recognized by the National Institute for Occupational Safety and Health and/or the EPA\nthat it poses acute or chronic health hazards, (iv) it is the subject of a Department of Health public\nhealth advisory, (v) has been classified as a likely human carcinogen by EPA, (vi) has been\nclassified as a Group 1 human carcinogen by IARC and (vii) exposure to PFOA is shown by expert\ntestimony to increase the risk of developing a serious latent disease.\n\n46. | PFOA exposure has also been linked in epidemiological studies to a number of\nnon-cancerous adverse health effects, including hypercholesterolemia, thyroid disease, ulcerative\ncolitis, elevated uric acid levels, and pre-eclampsia. PFOA\u2019s toxicity and persistence in the\nenvironment make it dangerous to human health and the environment.\n\n47. In May 2006, the EPA Science Advisory Board stated that PFOA cancer data are\nconsistent with guidelines suggesting exposure to the chemical is \u201clikely to be carcinogenic to\nhumans.\u201d These health conditions can arise months or years after exposure to PFOA. In August\n2022, the Science Advisory Board issued a final determination that PFOA is a \u201clikely carcinogen.\u201d\n\n48. | When humans are exposed to PFOA, this toxic chemical binds to plasma proteins\nin the blood and is readily absorbed and distributed throughout the body. The liver and kidneys\nare important binding and processing sites for PFOA, resulting in physiologic changes to these\n\nand other organs. Because of strong carbon-fluorine bonds, PFOA is stable to metabolic\n\n13\n\f2:26-cv-00291-kjd Document1 = Filed 08/25/26 Page 14 of 69\n\ndegradation, resistant to biotransformation, and has a long half-life in the body. This toxic\nchemical accumulates in the body over time and causes long-term physiologic alterations and\ndamage to the blood, liver, kidneys, immune system, and other organs.\n\n49. The C8 Science Panel identified kidney cancer and testicular cancer as having a\n\"probable link\" to PFOA exposure in the Mid-Ohio Valley population exposed to PFOA in\ndrinking water. Epidemiological studies of workers exposed to PFOA on the job support the\nassociation between PFOA exposure and both kidney and testicular cancer and also suggest\nassociations with prostate and ovarian cancer and non-Hodgkin's lymphoma. Rodent studies\nalso support the link with cancer.\n\n50. Additionally, the C8 Science Panel found a probable link between exposure to\nPFOA and the following human diseases: thyroid disease, pregnancy-induced hypertension,\nulcerative colitis, and high cholesterol. Furthermore, in recent years, immunotoxicity of PFOA\nand related compounds has been demonstrated in a wide variety of species and models, including\nhumans. For instance, a study of ninety-nine Norwegian children at age three found that maternal\nserum PFOA concentrations were associated with decreased vaccine responses, especially\ntoward rubella vaccine, and increased frequencies of common cold and gastroenteritis. The\ncombined human and experimental! evidence strongly supports adverse effects on immune\nfunctions at relatively low exposure levels.\n\n51. In 2022, the National Academies of Sciences, Engineering and Medicine\n(\u201cNASEM\u201d) issued a Consensus Study Report titled \u201cGuidance of PFAS Exposure, Testing and\nClinical Follow-Up. A distinguished panel of scientist from multiple disciplines was asked to\nadvise on per-and polyfluoroalkyl substances (\u201cPFAS\u201d) testing and clinical care for patients\n\nexposed to PFAS, which includes PFOA. To arrive at its conclusions, the Committee reviewed the\n\n14\n\f2:26-cv-00291-kjd Document1 = Filed 08/25/26 Page 15 of 69\n\ncurrent science regarding PFAS exposure and human health effects. The Committee recommends\nthat individuals who have 2 ppb of PFAS (including PFOA) in their blood or greater undergo\nPFAS medical screening for certain health effects associated with PFAS exposure.\n\n52. In 2023, the International Agency for Research on Cancer (\u201cIARC\u201d) classified\nPFOA as carcinogenic to humans (Group 1) and PFOS as possibly carcinogenic to humans (Group\n2B). In 2024, EPA concluded that both PFOA and PFOS are likely to be carcinogenic in humans.\n\n53. | Defendant DuPont received inquiries regarding the toxicity of PFOA as early as\n1954 and historical documents demonstrate a recognized concern for the toxicity of the chemical\nfrom the 1950s through the time it discontinued use of the chemical.\n\n54. Defendant Dupont conducted its first toxicological experiments with C-8 in 1961\nwhen it exposed rats to the chemical and found liver enlargement at virtually all doses. In this\ntimeframe, Defendant DuPont\u2019s scientists were already testing substitute chemicals that were\nlower in toxicity and cheaper to purchase in an effort to replace PFOA\n\n55. Internal historical documents from Defendant 3M show that company scientists\nwere aware of the health risks of PFOA as early as the 1960s.\n\n56. In 1976 researchers from the University of Rochester published a report that\nshowed widespread contamination of human tissues with organofluorine compounds (organic\ncompounds that contain the carbon-fluorine bond) which likely derived from commercial sources\nsuch as PFOA. The authors contacted Defendant 3M questioning whether its consumer products\ncontaining these compounds could be the source. J.D. LaZerte of Defendant 3M advised W.S.\nGuy, one of the researchers on the project, \u201cnot to speculate\u201d on the source of the organofluorine\ncompounds found in human tissues and, upon information and belief, 3M took no further action\n\nto investigate this issue.\n\n15\n\f2:26-cv-00291-kjd Document1 Filed 08/25/26 Page 16 of 69\n\n57. By 1978, Defendant DuPont knew from a Defendant 3M study that C-8 in the\nenvironment did not biodegrade.\n\n58. By 1978, Defendant 3M found elevated organic fluorine levels in the blood of its\nworkers exposed to fluorinated surfactants such as PFOA.\n\n59. | When Defendant DuPont learned of these elevated levels in Defendant 3M\u2019s\nworkers, it too documented high concentrations of PFOA in the blood of its factory workers at its\nWashington Works facility, showing that PFOA bioaccumulates and is not easily removed from\nthe body due to a half-life of 2-8 years.\n\n60. In 1978, Bruce Karrh, M.D., Defendant DuPont\u2019s Corporate Medical Director,\npublished an article in a professional journal stating: \u201cIt is the duty of every company\u2019s\nmanagement to discover and reveal the unvarnished facts about health hazards. . . [A] company\nshould disclose health-hazard information. It should be candid, and lay all the facts on the table.\nThis is the only responsible and ethical way to go. This approach is the correct one, of course and\nit is the way we try to proceed at DuPont.\u201d\n\n6l. By September of 1978, Defendant DuPont had reviewed medical records of 11\noperators and 18 laboratory workers with long-term exposure to PFOA and found that more of\nthem than anticipated had abnormal liver function tests.\n\n62. Inthe late 1970s, Defendant 3M consulted with Dr. Harold C. Hodge of the\nUniversity of Rochester. At a meeting in 1978, Dr. Hodge told Defendant 3M\u2019s Medical Director,\nDr. F.A. Ubel, that physical examination results of employees should be compared with controls.\n\u201cThere appears to be indications of liver change from the physical examination results. In terms of\nindicators of liver disorder, there are [sic] a higher percentage at Chemolite [a 3M facility] than at\n\nDecatur [another 3M facility] and the organically bound fluorine level at Chemolite is\n\n16\n\f2:26-cv-00291-kjd Document1 Filed 08/25/26 Page 17 of 69\n\ncorrespondingly higher.\u201d Dr. Hodge indicated to Defendant 3M at this time that a potential hazard\nwas present regarding organofluorine chemical exposure to its workers.\n\n63. A joint meeting was held in 1979 between Defendant 3M\u2019s fluorochemical\nexposure committee and Defendant DuPont\u2019s Eugene Berman and several colleagues. Both\ncompanies\u2019 representatives agreed that since there were no established adverse health effects\nassociated with the findings of accumulated fluorochemicals in the blood of workers at the two\ncompanies, there was no reason to provide an 8(e) notification under Toxic Substance Control\nAct (\u201cTSCA\u201d) to the EPA regarding these findings. Meeting minutes indicate that a discussion\ntranspired as to whether they would make any efforts to seek evidence of a possible association\nbetween worker blood levels and illness: \u201cDuPont was asked if they had carried out any chronic\nstudies on fluorochemicals in the past and if they planned any in the future. In both cases the\nanswer was negative. Fluorochemicals have a low priority in their chronic testing program. They\nwould not carry out such studies unless they were forced to by regulations.\u201d\n\n64. In 1979, Defendant DuPont found increased PFOA levels in the blood of eight\nworkers who worked in the FEP polymerization and TFE dispersion polymerization processes,\nwith the average blood level for PFOA among the eight workers being 8.2 ppm (8,200 ppb).\n\n65. In 1979, Defendant DuPont was aware that blood test results of its Washington\nWorks employees showed organic fluoride levels were associated with increases in liver enzyme\nlevels, indicating possible liver damage. Defendants DuPont and 3M were also aware that PFOA\nexposure caused adverse health effects both Rhesus monkeys and Charles River CD rats, but that\nthe \u201cmonkeys were more severely affected of the two.\u201d Both learned that \u201cthe data on monkeys\nsuggested increased incidences of chronic interstitial nephritis [kidney damage], hyperkeratosis\n\nin the skin and a slight increase in skeletal muscle atrophy ... Similarly, the data on rats suggest\n\n17\n\f2:26-cv-00291-kjd Document1 Filed 08/25/26 Page 18 of 69\n\nhepatocellular necrosis [liver damage], sinusoidal liver congestion and the presence of yellow-\nbrown pigment in the epithelium of the convoluted tubules of the kidney.\u201d The 90-day oral study\nin Rhesus monkeys had been administered at dosage levels of 0, 3, 10, 30 and 100 mg/kg/day of\nPFOA, with the monkeys receiving the highest dose dying during weeks 2-5 of the study, three\nof the monkeys receiving the 30 mg/kg/day dose also died during weeks 7-12 of the study while\nall monkeys exposed at this dose showed signs of toxicity in the gastrointestinal tract and other\nadverse changes. Monkeys dosed at the two highest levels also showed weight loss from the first\nweek of the study.\n\n66. In 1979, Defendant DuPont also learned that PFOA caused metabolic\nabnormalities in rats and altered immunochemical reaction of bovine (cow) serum albumin. It\nalso was aware at that time that: 1) PFOA caused liver enlargement in rats and death at high\ndoses; 2) increases in plasma enzyme levels indicative of cellular damage in dogs and death at\nhigh doses; and 3) inhaled doses in rats for only four hours could cause liver enlargement and\ncorneal opacity.\n\n67. Based upon the adverse health effects of PFOA on laboratory animals, in 1979\nDefendant DuPont established a provisional PFOA acceptable exposure level for its employees\nof 0.01 mg/m3 in air based upon an 8-hour time-weighted average exposure.\n\n68. _ Early PFOA toxicology studies commissioned by Defendant 3M were\nsummarized in 1980 with the liver was highlighted as a target organ, while effects on the\nimmune system were also reported. The study reports were not submitted to the EPA until 2000,\nthe same year Defendant 3M decided to stop manufacturing PFOA, but most, if not all reports,\nwere shared with Defendant DuPont years earlier.\n\n69. By 1980, Defendant DuPont had internally confirmed that PFOA \u201cis toxic,\u201d\n\n18\n\f2:26-cv-00291-kjd Document1 Filed 08/25/26 Page 19 of 69\n\n\u201cpeople accumulate\u201d the chemical in their bodies after exposure and \u201ccontinued exposure is not\ntolerable.\u201d At this same time, Defendant DuPont documented that sixteen of its workers had\nPFOA blood serum levels of between 4.97 ppm and 21.69 ppm (4,970 ppb and 21,690 ppb).\n\n70. In materials from a C-8 Communications meeting dated July 31, 1980, an\nemployee of Defendant DuPont stated: \u201cAfter 25 years of handling C-8, we see no damage\namong workers. However the potential is there \u2014 C-8 has accumulated in the blood. Because of\nthis accumulation we have decided to undertake programs to minimize accumulation of C-8 in\nthe blood in the workers.\u201d\n\n71. By 1981, Defendant DuPont was aware that PFOA in the blood serum of a pregnant\nwoman could cross the placenta to the fetus. PFOA was found to be present in the umbilical cord\nblood of an infant born to an employee and in the blood of an infant born to another employee.\n\n72.  Anexperimental study conducted by Defendant 3M in 1981 showed birth defects\nin the eye lens of rats exposed to PFOA. In March of 1981, Defendant 3M informed Defendant\nDuPont of the rat study, prompting DuPont to survey children born to PFOA exposed workers of\nits Teflon\u00ae Division. It found birth defects in two of seven children, both of whom had eye\ndefects. Defendant DuPont then removed all female employees from PFOA exposed jobs but\ndid not inform them of the reason for their transfer.\n\n73. By the early 1980\u2019s, Defendants DuPont and 3M were sharing their internal\nstudies concerning health and environmental effects associated with exposure to PFOA, but did\nnot share them publicly.\n\n74. In 1982, Defendant DuPont calculated that approximately 40 percent of the PFOA\nvapor inhaled was retained in the blood of human males.\n\n75. On November 23, 1982, Defendant DuPont\u2019s Medical Director, Bruce Karrh, MD,\n\n19\n\f2:26-cv-00291-kjd Document1 Filed 08/25/26 Page 20 of 69\n\nwrote in an internal memorandum: a) \u201cOur knowledge of the product health effects of long-term\nexposure to low levels of C-8 is quite limited\u201d; b) \u201cC-8 is retained in the blood for a long time,\ncreating concern in other areas such as blood donations, etc.\u201d; and c) \u201cAll employees, not just\nTeflon area workers, are exposed.\u201d\n\n76. By September of 1984, Defendant 3M\u2019s medical service team noticed an increasing\ntrend in worker organic fluorine concentrations in blood testing that had begun eight years earlier.\nThe team advised \u201cwe must view this present trend with serious concern . . . exposure\nopportunities are providing a potential uptake of fluorochemicals that exceeds excretion\ncapabilities of the body.\u201d\n\n77. Thereafter, Defendant 3M endeavored to search for any blood samples among its\nworkers that were free of organofluorine compounds. When this was unsuccessful, an internal 3M\ndocument proposed: \u201cIt is in the interest of 3M to strengthen the evidence of non-industrial sources\nof organic fluorine in normal human blood.\u201d 3M initiated efforts beginning in 1993 to show that\norganic fluorine in blood could be from entirely natural sources but it was unable to find any data\nto support this hypothesis leaving PFOA the probable source of these compounds in its\nemployees\u2019 blood.\n\n78. By June 14, 1984, Defendant DuPont was aware from analysis of blood testing of\nformer Teflon\u00ae Division employees that the average biological half-life of PFOA in human\nblood was approximately 2.4 years with considerable variability among individuals.\n\n79. On June 12, 1987, H.A. Smith of the Safety, Energy & Environmental Affairs\noffice of Defendant DuPont\u2019s Manufacturing Division made a request to DuPont\u2019s Haskell\nLaboratory that it establish an acceptable level of PFOA in the blood and in drinking water.\n\n80. On March 9, 1988, Defendant DuPont recommended a community exposure\n\n20\n\f2:26-cv-00291-kjd Document1 - Filed 08/25/26 Page 21 of 69\n\nguideline (\u201cCEG\u201d) for drinking water for PFOA of 1 ug/L (ppb). This was adopted by Defendant\nDuPont in June of 1991 and was intended to be protective for community consumption of PFOA\ncontaminated drinking water. It never advised its customers of its PFOA-containing products\nthat it had established a CEG for PFOA in drinking water.\n\n81. A 1990 Defendant DuPont internal industrial hygiene data review found PFOA\nblood levels an order of magnitude or more higher than the levels in PFOA-contaminated air,\nwhich demonstrated that PFOA bioaccumulated inside the human body.\n\n82. By 1990, Defendant DuPont was aware that PFOA was associated with increased\nrates of carcinogenicity in rats, including Leydig cell adenomas of the testis, which are precursor\nlesions to testicular cancer. In an April 12, 1990, memo entitled \u201cInvestigation of Hormonal\nMechanisms for C-8 Induced Leydig Cell Adenoma\u201d by Mark Hurtt and Jon Cook of Defendant\nDuPont\u2019s Haskell Laboratory, the authors reviewed data derived from a Defendant 3M animal\nstudy and concluded that the induction of Leydig cell adenoma related to PFOA exposure was\nlikely to be hormonally mediated and a similar human reaction could not be ruled out.\n\n83. By 1991 DuPont scientists were recommending that a warning about potential C-\n8 health hazards should be included in Material Safety Data Sheets for all products that\ncontained more than 0.1% or more of C-8, which included all Teflon\u00ae dispersion products.\n\n84. Also, by 1991, DuPont recognized that there was an increased incidence of certain\ncancers among employees of its Washington Works facility, including kidney and bladder\ncancers. A meeting was held to determine whether it should conduct a full-blown\nepidemiological study of this cancer incidence increase, at which it was concluded the company\nshould \u201cdo the study after we get sued.\u201d\n\n85. In the unpublished 1992 thesis of Frank Gilliland, MD, who studied the clinical\n\n21\n\f2:26-cv-00291-kjd Document1 Filed 08/25/26 Page 22 of 69\n\npathology parameters of 111 male workers at Defendant 3M\u2019s Cottage Grove Plant, Dr. Gilliland\nconcluded that PFOA may affect male reproductive hormones, and that thyroid effects in 3M\nproduction workers may be associated with organofluorine concentrations in worker blood\nserum.\n\n86. In 1993, Defendant DuPont\u2019s health experts recommended an attempt be made to\ncorrelate adverse health effects of workers with their level of exposure to PFOA. This\nrecommendation was rejected.\n\n87. By 1993, Defendant 3M began to monitor PFOA levels in the blood serum of its\nproduction workers and conducted a mortality study of such workers showing a three-fold excess\noccurrence of prostate cancer in workers employed more than ten years.\n\n88. By 1994, Defendant DuPont knew that C-8 was an animal carcinogen and caused\ntumors in the testis, liver and pancreas of test-animals. Its employee Michael Gell expressed his\nconcern about the safety of DuPont\u2019s Teflon\u00ae dispersion products when used by customers like\nthe SGPP Facilities: \u201cI am concerned that we may have a product stewardship issue if we have a\nfinish [Teflon\u00ae AFD product] that contains a suspect carcinogen that is made and processed on a\nDuPont site and then goes out to a potentially uniformed customer. If that customer does not\nhandle the product with adequate precautions there could be a backlash to DuPont as the\nsupplier.\u201d\n\n89. Later in 1994 at a meeting of the PTFE Toxicology Working Group attended by\nthe head of Defendant DuPont\u2019s Haskell Laboratory, Gerald Kennedy, the group discussed the\nfact that APFO had been determined to be an animal carcinogen and the implications of that\nfinding for people exposed to the chemical. They were concerned that this unregulated\n\nmanmade chemical would someday be regulated by governmental agencies. The minutes of this\n\n22\n\f2:26-cv-00291-kjd Document1 = Filed 08/25/26 Page 23 of 69\n\nmeeting state: \u201cThe group agreed that the currently available information was insufficient to\nallow a full evaluation of the implications of the carcinogenicity findings for human health. The\nlevel of concern was generally low and it was generally believed that occupational exposure\nlevels of the order of that recommended by ACGIH would be adequate. Of greater concern than\nthe finding of carcinogenicity itself was the apparent long half life of APFO in humans.\nNevertheless, it was recognized that these beliefs were based on conjecture and hypothesis, not\nfact. If the regulatory authorities were to be convinced, additional data was required.\u201d\n\n90. In 1994, Alan Ducatman, M.D., then Professor of Medicine at West Virginia\nUniversity School of Medicine, call\u00e9d Defendant DuPont\u2019s Medical Director Dr. Bruce Karrh\nand shared his opinion that PFOA was on the fast track to being identified as a potential human\ncarcinogen.\n\n91. In 1995, when Defendant 3M discussed Defendant DuPont\u2019s study results,\nshowing cancer in male rats exposed to PFOA, with colleagues from the UK company ICI,\nwhich used APFO in its manufacturing processes, ICI strongly espoused that APFO should be\nconsidered an animal carcinogen, as the benign tumors observed are simply early lesions that\nultimately lead to malignant tumors, but Defendant 3M representatives disagreed.\n\n92. A 1995 email from William Haaf, a toxicologist at Defendant DuPont\u2019s Haskell\nLaboratory to John Migliori, a DuPont employee involved in industrial hygiene, candidly stated\n\u201cT could make a case we have no idea what long term effects will or will not occur\u201d from\nexposure to PFOA.\n\n93. In 1996, Defendant DuPont\u2019s officials discussed establishing a medical\nsurveillance program for its workers exposed to PFOA. Such a program was never initiated. In\n\nApril of 2000, Defendant DuPont again rejected its occupational health official\u2019s\n\n23\n\f2:26-cv-00291-kjd Document1 - Filed 08/25/26 Page 24 of 69\n\nrecommendation for a comprehensive medical surveillance program for employees exposed to\nPFOA, noting that establishing such a program \u201ccould have significant repercussions at any of\nour other sites that handle . . . similar products.\u201d\n\n94. In 1996, Defendant DuPont established the C-8 Program with stated goals of\n\u201c[m]aintain[ing] a reasonable certainty [that PFOA exposure caused] no harm to human health\n[or] ... the environment.\u201d A central component of achieving that goal was for DuPont to\nconduct a \u201crisk analysis\u201d which would \u201crefine conditions which produce a reasonable certainty\nof no short- or long-term harm to human health and the environment.\u201d\n\n95. As part of the human health risk assessment, Defendants DuPont and 3M, and the\nAssociation of Plastic Manufacturers in Europe (APME) collaborated on a study exposing\nmonkeys to PFOA to better understand the toxicity of PFOA and the risk to human health (the\n\u201cMonkey Study\u201d).\n\n96. As of January of 1997, researchers at Defendant DuPont were aware of a\nhormonally mediated mechanism for the Leydig cell tumors in rat testes. In a document entitled\n\u201cHazard Characterization for Human Health in C8 Exposures, CAS Registry No. 3825-26-1,\u201d Lisa\nB. Biegel, Ph.D., Senior Research toxicologist at Defendant DuPont\u2019s Haskell Laboratory wrote:\n\u201cThe studies summarized below support a hormonally-mediated mechanism for the Leydig cell\ntumorigenesis: C8 produces an increase in hepatic aromatase activity, which elevates serum\nestradiol concentrations, which in turn modulates growth factors in the testes, which results in\ntumor formation.... The mechanism of tumorigenesis is not completely understood, and therefore\nrelevance to humans cannot be completely ruled out. However, it is known that non-genotoxic\ncompounds (such as C8) produce Leydig cell tumors by altering the endocrine system.\u201d\n\n97. A paper published in 1997 by John C. Cook of Defendant DuPont together with\n\n24\n\f2:26-cv-00291-kjd Document1 Filed 08/25/26 Page 25 of 69\n\nEric D. Clegg concluded: \u201cOccurrence of Leydig cell adenomas in test species is of potential\nconcern as both a carcinogenic and reproductive effect if this mode of induction and potential\nexposure cannot be ruled out as relevant for humans [and]... it should be assumed that humans are\npotentially susceptible.\u201d\n\n98. On October 22, 1999, Defendant DuPont received the results of the Monkey\nStudy including that one high dose monkey died from exposure as did one low dose monkey\nwith all doses causing increases in liver weight thereby increasing the chances of mutation and\nincreased risk of tumors.\n\n99. A month later, in November 1999, Defendants 3M and DuPont determined EPA\nhad to be advised of these results to comply with a federal law that requires disclosures of\ninformation about a chemical that indicates it presents a \"substantial risk of injury to health or\nthe environment\" and filed TSCA 8(e) disclosures with EPA.\n\n100. Asaresult of the Monkey Study results, Defendant DuPont\u2019s Haskell Laboratory\ndetermined that no safe level of exposure to PFOA in humans could be established.\n\n101. In March of 2000, Defendant DuPont abandoned its C-8 Program without\nconducting the planned human risk assessment and environmental risk assessment.\n\n102. Another goal of the C-8 Program had been to develop an alternative to PFOA in\nthe manufacture of its Teflon\u00ae fluoropolymer products. Several alternatives to PFOA were\nconsidered, but the one with the greatest potential and lowest toxicity, H4C8, was abandoned\nbecause its production cost would have reduced Defendant DuPont\u2019s AFD profit margin.\n\n103. When the C-8 Program was abandoned in March of 2000, Defendant DuPont\ndecided to continue to use PFOA and to abandon its goal of replacing the chemical with one that\n\nwas less toxic and less environmentally persistent.\n\n25\n\f2:26-cv-00291-kjd Document1 Filed 08/25/26 Page 26 of 69\n\n104. In April of 2000, EPA contacted Defendant DuPont and requested all information\nDefendant DuPont possessed relevant to PFOA, including: \u201chealth effects studies (including\npharmacokinetics), environmental fate studies and information, and human and environmental\nexposure studies and information, including monitoring.\u201d\n\n105. Inearly 2000, the EPA notified Defendant 3M that it intended to pursue more\nrigorous regulation of the perfluorinated chemicals 3M manufactured. In May of 2000,\nDefendant 3M announced it would stop manufacturing both PFOA and PFOS because of toxicity\nconcerns, and it stopped selling PFOA in approximately 2002. Upon information and belief,\nDefendant 3M made this decision to forgo selling a product that generated substantial revenue\nand a large profit margin due.to concerns of future liability and regulatory action.\n\n106. On June 23, 2000, Gerald Kennedy, head of Defendant DuPont\u2019s Haskell\nLaboratories, sent a letter to Charles Auer of EPA in response to EPA\u2019s inquiry with an\nattachment entitled Voluntary Use and Exposure Information Profile. This letter and attachment\ncontained numerous material misstatements of fact that Defendant DuPont knew or should have\nknown were false, including: a) a relatively small amount of APFO leaves Defendant DuPont\nfacilities in fluoropolymer dispersion products; b) greater than 97% of the APFO in dispersions\nwas destroyed in processing; c) most applications of its dispersion products involved a sintering\nstep where APFO was destroyed; d) there were only a \u201csmall number\u201d of applications where\ndispersion products were heated to temperatures where APFO would sublime resulting in air\nemissions.\n\n107. After Defendant 3M announced it would stop selling APFO by 2002, which\noccurred shortly after Defendant DuPont abandoned its C-8 Program seeking an alternative to\n\nAPFO, Defendant DuPont scrambled to find a new source of APFO for use in production of its\n\n26\n\f2:26-cv-00291-kjd Document1 Filed 08/25/26 Page 27 of 69\n\nTeflon\u00ae products and established a Steering Team to evaluate alternative strategies to secure a\nfuture supply of APFO. That Steering Team developed a \u201cLiability Continuum\u201d to evaluate\nfuture liability risk to Defendant DuPont for each of the possible alternatives and eventually\nconcluded that making APFO for its own internal use and not selling it to competitors was the\nbest balance between maintaining profitability and reducing future liability risk.\n\n108. In early 2001, Defendant DuPont announced its decision to build an APFO\nmanufacturing facility in Fayetteville, N.C. so it could continue to manufacture fluoropolymer\nproducts including AFD with APFO after Defendant 3M ceased selling the chemical.\n\n109. In March of 2002, a Defendant DuPont website titled \u201cC-8 INFORM\u201d continued to\nstate that PFOA had no adverse health effects: \u201cIn more than 50 years of C-8 use by DuPont and\nothers, there have been no known adverse human health effects associated with the chemical. 3M\nand DuPont studies, as well as extensive other scientific data, support the position of no known\nadverse human health effects associated with C-8.\u201d\n\n110. In 2003, Defendant 3M conducted a mortality study of its workers exposed to\nPFOS, a chemical in the PFAS family closely related to PFOA, and reported excess bladder\ncancer incidence with high exposure jobs.\n\n111. A mortality registry kept by Defendant DuPont demonstrated an excess of kidney\ncancer deaths over expected levels for workers at the Washington Works plant.\n\n112. Onor about July 7, 2004, EPA filed a formal complaint against Defendant\nDuPont for TSCA reporting violations based upon its withholding of important information\nabout PFOA toxicity from EPA. A settlement was reached that required Defendant DuPont to\npay the largest civil administrative penalty in EPA history at the time.\n\n113. After Defendant DuPont began manufacturing APFO and continued to use it to\n\n27\n\f2:26-cv-00291-kjd Document1 Filed 08/25/26 Page 28 of 69\n\nmanufacture its AFD products, it deliberately distributed misinformation to its customers and the\npublic that exposure to PFOA was safe. Defendant DuPont established an Epidemiology Review\nBoard comprised of independent epidemiologists and scientists to add credence to its public\nstatements that PFOA was not harmful to humans. However, in March of 2006, the members of\nthis review board pushed back against those statements, telling Defendant DuPont in a memo\n\u201cWe believe no party can claim sufficient knowledge that PFOA does or does not pose any risk\nto health. Thus, we question the evidential basis of DuPont\u2019s public expression asserting that\nPFOA does not pose a risk to health.\u201d\n\nDefendant SGPP\u2019s Knowledge of Potential PFOA Risk to Human Health\n\n114. On February 27, 1995, a contingent from Defendant DuPont visited the Chemfab\nfacility in North Bennington to exchange information about Defendant DuPont\u2019s products.\nDuring this meeting, Defendant DuPont\u2019s Robert Cavanaugh told Chemfab representatives that\nDefendant DuPont decided to eliminate APFO in their homopolymer and FEP polymerization\nprocess because APFO accumulates in the body, is eliminated very slowly and has been shown\nto cause tumor growth in laboratory animals.\n\n115. On March 17, 1995, Robert Cavanaugh had another meeting with Chemfab\nrepresentatives. At that time, Mr. Cavanaugh informed Chemfab that Defendant DuPont\u2019s\nmanagement issued a decree to remove APFO from its products because of its toxicity and long\nhalf-life.\n\n116. In September of 1998, Mr. Cavanaugh made a presentation to Chemfab during\nwhich he discussed the reported health concerns surrounding exposure to PFOA, and Defendant\nDuPont\u2019s efforts to replace APFO in its dispersions with a chemical called FS-62.\n\n117. In July of 1999, representatives of Chemfab Europe met with representatives of\n\n28\n\f2:26-cv-00291-kjd Document1 Filed 08/25/26 Page 29 of 69\n\nICI, another manufacturer of AFD located in Europe. During this meeting Chemfab was\ninformed the Monkey Study was underway to determine the toxicity of PFOA in primates as\nwell as the efforts by ICI to replace APFO in its AFD with a \u201cgreen surfactant\u201d. A discussion\nalso occurred regarding methods of destruction of PFOA released from AFD at customer\nfacilities.\n\n118. In July of 2000, Defendant DuPont and Chemfab began discussing a more\ncomprehensive exchange of information about PFOA. Representatives from Chemfab traveled\nto Defendant DuPont\u2019s Washington Works facility in West Virginia in early 2001 for a series of\nmeetings during which Defendant DuPont disclosed some of its information regarding PFOA\ntoxicity and control of PFOA emissions.\n\n119. In May of 2001, Defendant DuPont chemist Danielle Lindner met with Defendant\nSGPP representatives to discuss, among other things, Defendant SGPP\u2019s concerns about phasing\nout of APFO in AFD.\n\n120. In August of 2002, Defendant SGPP closed its facility in North Bennington,\nVermont and moved all of its fabric coating operations to Merrimack, New Hampshire.\n\n121. JInamemo dated October 16, 2002, Douglas Hayes of Defendant DuPont recounts\ndiscussions he had with Defendant SGPP representatives about APFO. In the memo, Hayes\nstates \u201cS-G acknowledged that we have been talking to them about C-8 issues a long time, we\u2019ve\nbeen encouraging them to do a mass balance, etc.\u201d to determine the amount of APFO that was\nreleased into the environment.\n\n122. In December of 2002, representatives of Defendant DuPont visited Defendant\nSGPP\u2019s facility in Merrimack to discuss testing methodologies that could be utilized to\n\ndetermine the amount of PFOA Defendant SGPP was releasing from its fabric coating ovens.\n\n29\n\f2:26-cv-00291-kjd Document1 Filed 08/25/26 Page 30 of 69\n\nUp to this point, neither Chemfab nor Defendant SGPP had tested for PFOA emissions.\n\n123. By early 2003, Defendant SGPP established a Stack Testing Team to plan for\ntesting to determine how much PFOA was being released from its fabric coating ovens in\nMerrimack, New Hampshire. By late January of 2003, the name of this team changed to APFO\nMaterial Balance Team.\n\n124. Up until approximately 2003, Defendant SGPP and its predecessor Chemfab\nroutinely added Defendant 3M\u2019s product FC-143 (pure APFO) to some of its AFD formulations\nto improve the AFD\u2019s wetting properties. By April of 2003, Defendant SGPP stopped adding\nFC-143 to most of its formulations but continued to add it to some others.\n\n125. In July of 2003, Defendant SGPP established a group to facilitate communications\non the APFO/PFOA issue and assigned \u201cTymor\u201d as a code name for the group to be used instead\nof referring in communications to the chemicals themselves.\n\n126. In August of 2003, Defendant SGPP received a copy of a letter and attachment\nsent from Defendant 3M to EPA. The attachment contained information about APFO/PFOA\nincluding that PFOA was highly water soluble and that testing it did not degrade in the\nenvironment.\n\n127. Also, in August of 2003, Defendant SGPP agreed to join a Processor Advisory\nGroup to work with the Fluoropolymer Manufacturer\u2019s Group (FMG) of the Society for the\nPlastics Industry (SPI) to foster communications between manufacturers and processors\nconcerning APFO hazards and regulation by the government.\n\n128. In September of 2003, a briefing was provided to Defendant SGPP\u2019s parent\ncompany CEO in Evian, France by the Tymor team to update the parent company on the\n\nAPFO/PFOA issue. In that presentation, PFOA air emissions were recognized as likely from the\n\n30\n\f2:26-cv-00291-kjd Document1 Filed 08/25/26 Page 31 of 69\n\ndispersion coating process. At that meeting, the Processor Mass Balance Study, which was\nbeing sponsored by SPI and conducted by Barr Engineering, was discussed. This study was\nexpected to quantify air, water, and solid PFOA emissions from dispersion processing at SGPP\u2019s\nMerrimack facility. There was also going to be PFOA emission testing at Defendant SGPP\u2019s\nfabric coating facility located in Kilrush Ireland.\n\n129. In the 2003 presentation to management, the Tymor team explained that APFO\nwas used in two of Defendant SGPP\u2019s divisions that involved millions of dollars of high-margin\nsales. The proposed plan was to follow a \u201cShadow\u201d strategy to keep Defendant SGPP less\nvisible to the media, customers, and public about the PFOA issue and \u201cout of the public spotlight\nand allowed the company to \u201canonymously evaluate pathways and amounts of APFO released to\nthe environment.\u201d\n\n130. In December of 2003, Defendant SGPP received the results of Barr\u2019s mass\nbalance emission testing of two coating towers at Merrimack, which were similar or identical to\nthe coating towers formerly utilized in North Bennington. Barr\u2019s testing demonstrated that 8%\nof the APFO in the AFD was released into the air as PFOA for one tower and 11% for the other.\nThis demonstrated conclusively that PFOA was not entirely destroyed when heated during the\nfabric coating process.\n\n131. Several months later in early 2004, Defendant SGPP received the results of Barr\u2019s\ntesting of a third coating process at its Merrimack facility. Specifically, it tested emissions from\nan oven heated with infrared radiation. That oven released 39% of the APFO in the AFD into\nthe air as PFOA.\n\n132. The Barr Processor Mass Balance Report was released by Barr in February of\n\n2005. As per the study design, it did not identify the companies that participated in the testing,\n\n31\n\f2:26-cv-00291-kjd Document1 Filed 08/25/26 Page 32 of 69\n\nonly the results of the testing. Barr found that recirculating ovens such as those tested at\nDefendant SGPP\u2019s Merrimack facility released between 9 and 19% of the APFO in the AFD as\nPFOA into the air and the non-recirculating ovens such as the one tested later in Merrimack\nreleased between 39 and 54% of the APFO in the AFD as PFOA into the air.\n\n133. On July 19, 2005, Ed Canning, Defendant SGPP\u2019s Global Director of\nEnvironment, Health and Safety, authored a memo to management to provide an update on the\nPFOA Fluorosurfactant Issue. In this memo, Canning references the finding by the EPA\nScientific Advisory Board that PFOA was a likely human carcinogen. He also describes\nDefendant SGPP\u2019s \u201cstrategy relative to staying in the background on this issue,\u201d and recites\nconcerns of the Tymor group that growing media interest in the PFOA topic may lead to the\neventual connection to Defendant SGPP.\n\n134. Defendant SGPP retained a consultant to perform PFOA air dispersion modeling\nat its fabric coating facility in Kilrush, Ireland. In October of 2005, it received the results of that\nstudy demonstrating that PFOA released into the air from its fabric coating operation, which was\nidentical to the process formerly utilized in North Bennington, traveled through the air and was\ndeposited in the communities surrounding the plant.\n\n135. In accordance with its \u201cShadow\u201d strategy, Defendant SGPP decided not to test the\narea around the Water Street Plant and, as a result, caused southern Bennington and Shaftsbury\nresidents to be consume PFOA contaminated water for more than a decade before this testing\nwas finally conducted.\n\n136. In early March of 2016, as a result of the discovery of PFOA contamination in\ngroundwater and potable water supply wells in North Bennington, the VTDEC, based on the\n\nrecommendation of the Vermont Department of Health (\"VTDOH\"), set a Vermont drinking\n\n32\n\f2:26-cv-00291-kjd Document1- Filed 08/25/26 Page 33 of 69\n\nwater Health Advisory Limit \u201c(WHAL\u201d)/interim groundwater enforcement standard for PFOA of\n20 ppt, or 0.02 ppb. In December 2016, VTDEC adopted a final rule setting a permanent\ngroundwater enforcement standard of 20 ppt.\n\nKnowledge of PFOA Environmental Contamination\n\n137. In 1966, Defendant DuPont became aware that perfluorochemicals including\nPFOA move rapidly in groundwater and migrate into nearby bodies of water.\n\n138. By August 31, 1966, Defendant DuPont became aware that, without pretreatment,\na small amount of perfluorocarboxylic acid (the class of pefluorochemicals to which PFOA\nbelongs) dispersing agent, deposited in a landfill would be leached into the groundwater.\n\n139. By May 13, 1975, Defendant DuPont employees in a memo entitled\n\u201cInvestigation of Current Teflon\u00ae Waste Disposal\u201d stated: \u201cThe problems with disposing of\n\u2018Teflon\u2019 waste are fear of toxicity, either from \u2018Teflon\u2019 itself or additives in some products.\nAlthough fears of contamination of underground water supplies by \u2018Teflon\u2019 scrap may be\nexaggerated, the possibility of small amounts of undesirable materials such as \u2018Triton\u2019\u00ae and C-8\nbeing present does exist. For this reason, we have elected to not landfill \u201cTeflon\u2019 waste at the\nlocal landfill, where large quantities of underground water serving both the Plant and the\nsurrounding area are present.\u201d\n\n140. In 1982, Defendant DuPont knew that PFOA from its Washington Works facility\nwas contaminating the Ohio River and could be present in drinking water that came from the\nOhio River. An internal DuPont memo dated October 19, 1982 cited analysis and projections of\nestimated human PFOA exposure from drinking contaminated Ohio River water.\n\n141. On November 23, 1982, Defendant DuPont\u2019s then Medical Director, Bruce Karrh,\n\nMD, stated in an internal memorandum that \u201c[t]here is obviously great potential for current or\n\n33\n\f2:26-cv-00291-kjd Document1_ Filed 08/25/26 Page 34 of 69\n\nfuture exposure of members of the local community from emissions leaving the Plant perimeter.\u201d\n\n142. By 1984, Defendant DuPont was aware that PFOA in particulate form exhausted\nfrom stacks at its Washington Works plant was carried by the wind well beyond the Washington\nWorks plant property line and deposited in the soil throughout the community. Defendant\nDuPont also learned that the drinking water supplies in communities around the Washington\nWorks plant were contaminated with PFOA, presumably from air discharges from the plant of\nparticulate matter that dissolved in rainwater and percolated into the groundwater and from direct\ndischarges of liquids containing PFOA into the Ohio River.\n\n143. By 1984, Defendant DuPont began a program of secretly collecting samples of\ntap water from public drinking water supplies near the Washington Works plant and testing these\nsamples for PFOA. DuPont found that PFOA was present in drinking water samples collected\nfrom locations in both Ohio and West Virginia in the vicinity of its Washington Works facility in\nboth Ohio and West Virginia.\n\n144. By June of 1984, Defendant DuPont was aware that water supplied by the town of\nLittle Hocking, Ohio, which was located \u201cup-river\u201d from the Washington Works plant contained\nPFOA levels of at least 500 ppt. Because of the location of the contaminated wells in Little\nHocking upstream from the Washington Works facility, Defendant DuPont knew that these wells\nwere contaminated by air emissions from Washington Works. Although Defendant DuPont knew\nthat PFOA was persistent in the environment and that it was continuing to release PFOA into the\nair meaning that such releases would likely increase the PFOA contamination in Little Hocking\u2019s\ndrinking water, Defendant DuPont chose not to alert local, state or federal officials or the public.\n\n145. By 1985, Defendant DuPont was aware that PFOA was leaching into groundwater\n\nfrom onsite ponds where it has previously disposed of PFOA contaminated sludge and that the\n\n34\n\f2:26-cv-00291-kjd Document1 Filed 08/25/26 Page 35 of 69\n\nPFOA was migrating through the groundwater into the public drinking water supply of Lubeck,\nWest Virginia, where Defendant DuPont found PFOA levels as high as 1,500 ppt. These PFOA\nlevels increased to 1,900 ppt in 1987 and 2,200 ppt in 1988.\n\n146. By 1987, Defendant DuPont conducted air modeling at its Washington Works\nfacility that documented PFOA in the ambient air beyond the fence line of the property and\ndrifting with the wind into nearby communities confirming what it already knew from\ncontamination of the Little Hocking wells.\n\n147. On June 11, 1987, Dr. Karrh, Defendant DuPont\u2019s Medical Director, told DuPont\nofficials that the Washington Works plant needed to give \u201chighest priority\u201d to issues associated\nwith the presence of PFOA outside the boundaries of the plant.\n\n148. In January of 1992, Defendant DuPont completed its purchase of the\ncontaminated Lubeck wellfield. It then tested the new wells that were being used by the Lubeck\ncommunity for drinking water and found that these wells had even higher levels of PFOA than\nthe old wells, even though the new wells were two miles further away from the Washington\nWorks plant. DuPont chose not to disclose its findings regarding the PFOA levels in the new\nLubeck wells. The contamination of these wells was not made public until 2001 when the West\nVirginia Division of Environmental Protection tested the drinking water in Lubeck.\n\n149. Defendants DuPont and 3M shared information about the environmental\ncontamination potential of fluorochemicals, such as PFOA and PFAS, from as far back as the\n1980s and the information alleged to be known by one was made known to the other.\n\n150. It was determined that the contamination of groundwater used for drinking water\nby the communities surrounding Defendant DuPont\u2019s Washington Works Plant discovered in the\n\nearly 1980s resulted principally from air emissions from DuPont\u2019s PTFE fine powder\n\n35\n\f2:26-cv-00291-kjd Document1 Filed 08/25/26 Page 36 of 69\n\nmanufacturing operations. PTFE fine powder and AFD were manufactured by Defendant\nDuPont from the same basic material, a dispersion containing water, PTFE particles, APFO and\nanother surfactant. Fine powder was created by drying this dispersion. AFD was created by\nprocessing this dispersion by creating and removing a supernate, which reduces the amount of\nAPEO in the final dispersion sold to customers.\n\n151. Defendant DuPont learned by the mid-1980s that by heating the dispersion to dry\nand create fine powder, the APFO in the dispersion vaporized into PFOA and was released into\nthe air where it fell out and contaminated groundwater. Defendant DuPont experimented with\nand later installed scrubbers to remove PFOA from the fine powder dryer exhaust and recycle it\ninto APFO for reuse.\n\n152. Although Defendant DuPont was aware that heating the dispersions above 150\u00b0 C\nresults in the release of PFOA into the air and that its AFD customers heated the dispersions\nabove that temperature in their processes, Defendant DuPont never warned or advised its\ncustomers in its MSDS sheets or other product literature that this would occur.\n\nPFOA Drinking Water Limits\n\n153. In 2009, the EPA identified PFOA as an emerging contaminant of concern and\nissued a provisional health advisory stating that short term (weeks to months) exposure to PFOA\nat a concentration of 400 ppt can cause human health effects. The provisional health advisory\nstated that the discovery of PFOA in water above the advisory level should result in the\ndiscontinued use of the water for drinking or cooking.\n\n154. Following the EPA\u2019s action, in 2013, New Jersey established a preliminary\nhealth-based guidance level of 0.04 ppb (40 ppt) in drinking water.\n\n155. In 2016, Vermont established a drinking water advisory of 0.02 ppb (20 ppt).\n\n36\n\f2:26-cv-00291-kjd Document1 - Filed 08/25/26 Page 37 of 69\n\n156. In May 2016, the EPA replaced its 2009 provisional health advisory with a new\nlifetime health advisory. The 2016 lifetime health advisory established that the presence of\nPFOA in drinking water at a concentration greater than 70 ppt should require water systems to\nundertake remediation and public health officials to promptly notify consumers about the health\nrisks associated with exposure to PFOA. The EPA health advisories are non-enforceable on the\nstates. EPA also established a Reference Dose (RfD) of 0.000002 mg/kg/day. The Reference\nDose is defined by EPA as an \u201cestimate[{] (with uncertainties spanning perhaps an order of\nmagnitude) of the daily exposure to the human population (including sensitive subgroups) that is\nlikely to be without an appreciable risk of deleterious effects during a lifetime.\u201d 3\n\n157. In June 2024, the EPA promulgated the PFAS/PFOA National Primary Drinking\nWater Regulation (NPDWR) Maximum Contaminant Level (MCL) of 4 ppt. It set the MCL\nGoal (MCLG), a non-enforceable health-based goal, of 0 ppt based on EPA\u2019s findings that these\ntwo compounds are likely carcinogenic in humans and in recognition of that the \u201clatest science\nshow{s] that there is no level of exposure to [PFOA and PFAS] without risk of health impacts.\u201d4\n\n158. As of January 31, 2026, Vermont implemented a new Groundwater Protection\nRule, setting its PFOA drinking water allowable level to 4 ppt.\n\n159. In May 2026, the EPA upheld the PFOA MCL of 4 ppt.\n\nThe Town of Shaftsbury\n\n160. The Town of Shaftsbury has a population of approximately 3,598 individuals and\n\nis located approximately 1.5 miles north of Defendant SGPP\u2019s facility in North Bennington.\n\n3 United States EPA, Health Effects Support Document for Perfluorooctanoic Acid (PFOA), p. 4-\n1 (May 2016).\n\n4 US EPA, Final PFAS National Drinking Water Regulation (April 2024),\nhttps://www.epa.gov/system/files/documents/2024-04/drinking-water-utilities-and-professionals-\ntechnical-overview-of-pfas-npdwr.pdf (last visited August 19, 2026).\n\n37\n\f2:26-cv-00291-kjd Document1 Filed 08/25/26 Page 38 of 69\n\n161. The Town of Shaftsbury has 927 private residential wells.\n\n162. Of the 927 private wells, 74 wells are less than 100 feet deep, making them more\nsusceptible to contamination from air deposition of PFOA.\n\n163. Dozens of private wells in the Town of Shaftsbury have tested positive for PFOA\ncontamination and testing is ongoing.\n\n164. Soil testing within the Town of Shaftsbury has revealed PFOA levels measured in\nsoil above the Federal Regional Screening Level for residential use of 0.019 pg/kg.\n\nThe Town of Bennington\n\n165. Residences located in southeast area of the Town of Bennington are not serviced\nby the Town of Bennington public water system and derive their drinking water from private\nwells.\n\n166. Dozens of private wells in this region have tested positive for PFOA\ncontamination and testing is ongoing.\n\n167. Soil testing within the Town of Bennington has revealed PFOA levels measured in\nsoil above the Federal Regional Screening Level of 0.019 pg/kg.\n\nSGPP Facilities\u2019 Background and Ownership History\n\n168. The VIDEC has identified Defendant SGPP\u2019s former manufacturing facility\nlocated at 1030 Water Street in North Bennington (the \u201cWater Street Plant\u2019) as the source of\nPFOA contamination in the local groundwater aquifer and numerous private drinking water\nsupply wells in and around Shaftsbury and southern Bennington.\n\n169. The Water Street Plant was operated by Defendant SGPP and its predecessor\nChemfab from approximately 1977 through 2002 and was engaged in the manufacture of\n\nTeflon\u00ae coated woven fiberglass fabrics. Defendant SGPP and its predecessor Chemfab utilized\n\n38\n\f2:26-cv-00291-kjd Document1 Filed 08/25/26 Page 39 of 69\n\nperfluorinated chemical solutions containing PFOA in the manufacturing operations at the Water\nStreet Plant.\n\n170. Upon information and belief, Chemical Fabrics Corporation, then a Delaware\ncorporation, began the manufacturing operations described herein at a facility located on\nNorthside Drive in Bennington, Vermont (the \u201cNorthside Drive Plant\u201d) in or about 1969 under\nthe trade name \u201cChemfab.\u201d\n\n171. PFOA contamination has been found in the local groundwater aquifer and private\ndrinking water supply wells around the Northside Drive Plant.\n\n172. In late 1977, Chemical Fabrics Corporation moved its manufacturing operations\nfrom the Northside Drive Plant in Bennington to the Water Street Plant in North Bennington.\n\n173. In December of 1983, Chemical Fabrics Corporation acquired legal title to the\nproperty on which the Water Street Plant is situated via property transfer from the Bennington\nCounty Industrial Corporation.\n\n174. In November of 1991, Chemical Fabrics Corporation adopted Chemfab\nCorporation as its legal name. In 1999, Chemfab\u2019s sales were over $126 million,\n\n175. Upon information and belief, Defendant SGPP\u2019s predecessor Chemfab worked\nclosely with Defendants DuPont in the use of PFOA-containing solutions for coating fabrics,\nincluding roofing fabrics, at the Northside Drive Plant and Water Street Plant.\n\n176. Inor about August of 2000, Defendant Saint-Gobain acquired Chemfab for $171\nmillion through a Merger Agreement by which Norton Company, a wholly owned subsidiary of\nDefendant SGPP, purchased all of Chemfab\u2019s outstanding shares of stock and options, and\nassumed its net financial debt.\n\n177. As aresult of the 2000 Merger Agreement, Defendant SGPP assumed any and all\n\n39\n\f2:26-cv-00291-kjd Document1 Filed 08/25/26 Page 40 of 69\n\nliabilities of Chemfab, including any and all liabilities related to or arising out of Chemfab\u2019s\nmanufacturing operations in Vermont, including at the Northside Drive Plant and Water Street\nPlant.\n\n178. Following the acquisition of Chemfab, Defendant SGPP continued the\nmanufacturing operations described herein at the Water Street Plant in North Bennington. As of\nMay 2001, SGPP became record owner of the property on which the Water Street Plant is\nsituated.\n\n179. In July of 2001, Defendant SGPP announced that it would close the Water Street\nPlant by August of 2002, eliminating approximately 90 jobs. This decision was due, in part, to\nSGPP\u2019s desire to avoid compliance with Vermont\u2019s air pollution regulatory standards.\n\n180. Defendant SGPP planned to move the Water Street Plant\u2019s manufacturing\noperations to other locations, including Merrimack, New Hampshire, as Vermont required\ncertain emissions abatement equipment to reduce and clean-up air emissions that was not\nrequired in New Hampshire, making New Hampshire a more attractive regulatory market for\nSGPP manufacturing operations.\n\nSGPP Facilities\u2019 Operations and PFOA Use/Disposal\n\n181. Chemfab began AFD coating operations at a facility located on Northside Drive\nin Bennington in or about 1969. The fabric coating operations were relocated to a larger facility\nlocated on Water Street in North Bennington in 1978 and expanded.\n\n182. The Teflon\u00ae-coated woven fabrics manufactured by Defendant SGPP at the\nSGPP Facilities were used in a wide variety of commercial and industrial applications, including\nas roofing material for large structures such as dome roofs, laminate substrate for circuit boards,\n\nand cooking sheets.\n\n40\n\f2:26-cv-00291-kjd Document1 Filed 08/25/26 Page 41 of 69\n\n183. Defendant SGPP\u2019s manufacturing operations at the Water Street Plant consisted\nprimarily of the application of Teflon\u00ae coatings to fiberglass fabrics in up to 13 coating lines,\nwhere the fabrics were dip coated in AFD (Teflon\u00ae) containing APFO.\n\n184. The coated fiberglass was then pulled through a fabric coating oven (tower) which\nhad three separate heating zones. The first zone, referred to as the drying zone, had temperatures\nranging from 30-100\u00b0 C where the water in the AFD evaporated into water vapor and was\nexhausted out of the oven. In the drying zone, APFO in the AFD began to sublimate into PFOA\nvapor and was exhausted out of the oven. The second zone, referred to as the baking zone, had\ntemperatures ranging from 200-300\u00b0 C and the remaining APFO in the AFD sublimated to\nPFOA and was exhausted out of the oven together with the other surfactant in the AFD, Triton-\nX. The final zone, referred to as the sintering zone, had temperatures ranging from 370-420\u00b0 C\nwhere the PTFE particles in the AFD were then fused to the fiberglass cloth creating the final\nproduct. The exhaust from each vertical oven was released into the air through each zone of the\ncoating line\u2019s tower, releasing PFOA vapor into the atmosphere.\n\n185... Upon information and belief, Defendant SGPP also operated ovens (towers) that\ncoated APFO-containing FEP dispersions onto fabric. FEP dispersions could not be sintered,\nand thus, these coatings were processed in ovens that did not utilize a sintering zone. When FEP\ndispersions were heated, they released PFOA vapor into the air in a similar fashion to other AFD\nas described above.\n\n186. As the PFOA vapors cooled, the PFOA returned to its solid phase as fine\nparticulate matter and was carried by the wind until precipitating out of the air either through\nprecipitation or gravity and deposited on the soils within the Town of Shafisbury, the Town of\n\nBennington and beyond.\n\n4]\n\f2:26-cv-00291-kjd Document1 = Filed 08/25/26 Page 42 of 69\n\n187. Once the PFOA particulate matter reached the soil, it dissolved into rainwater or\nsnow melt and was carried down to the groundwater where it has remained and will remain\nbecause PFOA does not degrade in the environment.\n\n188. Some of the ovens (towers) at the Water Street Plant were equipped with abaters,\nwhich were thermo-catalytic control devices. Defendant SGPP and its predecessor Chemfab\nnever tested these devices for efficiency of removing PFOA vapors from exhaust and these\ndevices were not designed or intended for PFOA removal from exhaust.\n\n189. Defendant SGPP\u2019s manufacturing operations at the Water Street Plant resulted in\nat least 30 air quality complaints to the VTDEC\u2019s Air Pollution Control Division between 1977\nand 2000. Most of these complaints pertained to noxious odors released from the Plant, while\nothers dealt with large amounts of smoke and/or visible emissions from the Plant.\n\n190. Defendant SGPP\u2019s manufacturing operations at the Water Street Plant resulted in\nmultiple enforcement actions brought by the VTDEC\u2019s Air Pollution Control Division against\nDefendant SGPP due to odors and/or other issues related to the Plant\u2019s air emissions.\n\n191. In addition to its air emissions, Defendant SGPP routinely discharged wastewater\nthat contained PFOA, derived from removing AFD from equipment, AFD spills, and rinsing of\nAED containers, into floor drains throughout the SGPP Facilities. Surplus AFD that contained\nPFOA were put into barrels and compacted outside the Water Street Plant, resulting in\ndischarges onto the ground and into nearby Paran Creek. Defendant SGPP and its predecessor\nalso discharged wastewater containing PFOA through one or more pipes to the exterior of the\nSGPP Facilities, which also flowed onto the ground and into nearby waterways. These various\ndischarges of PFOA into the environment resulted in contamination of the soil, surface water,\n\nand groundwater around the SGPP Facilities.\n\n42\n\f2:26-cv-00291-kjd Document1 Filed 08/25/26 Page 43 of 69\n\n192. Throughout the operation of the SGPP Facilities, Defendant SGPP never tested air\nemissions or wastewater emissions for PFOA.\n\n193. Upon information and belief, due to inadequate and unsafe practices related to the\nhandling, cleanup, and/or disposal of PFOA by Defendants at the SGPP Facilities, Defendant\nSGPP and its predecessor emitted, leaked, spilled, dumped, released, or otherwise discharged\nPFOA from these facilities into soil, sediments, groundwater, and/or surface waters, thereby\ncausing environmental contamination around the facilities, including the contamination of the\nlocal groundwater aquifer and numerous private drinking water supply wells.\n\nDiscovery of PFOA Contamination by the VIDEC\n\n194. In early February 2016, in response to the discovery of PFOA contamination from\na SGPP facility in nearby Hoosick Falls, New York, the VTDEC sampled private drinking water\nwells and two commercial wells near the site of the Water Street Plant in North Bennington for\nthe presence of perfluorinated chemicals. All five of the wells were found to contain PFOA at\nlevels above VHAL of 20 ppt.\n\n195. Based on these sampling results, the VTDEC, in early March of 2016 developed\nan initial sampling plan of all private drinking water wells and water sources, including surface\nwater and sediments, within a 1.5-mile radius of the Water Street Plant. The State of Vermont\nalso provided bottled water to all residents within this 1.5-mile radius until all impacted water\nsources could be determined.\n\n196. As part of this initial sampling plan, VTDEC sampled approximately 180 private\ndrinking water wells within a 1.5-mile radius of the Water Street Plant. The analytical results\nfrom this sampling showed that approximately 116 of these wells were contaminated with some\n\nlevel of PFOA contamination, and that approximately 105 of these wells were contaminated with\n\n43\n\f2:26-cv-00291-kjd Document1 Filed 08/25/26 Page 44 of 69\n\nlevels of PFOA in excess of 20 ppt.\n\n197. In early March 2016, the VTDEC notified Defendant SGPP that it was likely\nresponsible for the PFOA contamination around the Water Street Plant and formally requested\nthat Defendant SGPP commit to a series of actions to address the resulting threat to public\nhealth, welfare, and the environment.\n\n198. In mid-March of 2016, based on the results of the initial sampling plan, the\nVTDEC expanded its sampling of private drinking water wells into three areas outside the\noriginal 1.5-mile radius around the Water Street Plant. Of the approximate 50 wells sampled in\nthese three expanded areas, 28 wells contained some level of PFOA contamination, and 19 of\nthese wells contaminated with levels of PFOA in excess of 20 ppt. Furthermore, five monitoring\nwells at the Bennington Landfill showed levels of PFOA contamination between 18 ppt and 140\nppt.\n\n199. In early April 2016, the VTDEC again expanded the sampling area and\nannounced that it would be conducting \"spot check\" samples outside of this expanded area\nincluding near Shaftsbury.\n\n200. In late April 2016, the VTDEC again expanded the sampling area to include\nadditional areas around the Northside Drive Plant as well as areas around the Kocher Drive\nDump.\n\n201. Between February and mid-April of 2016, the VITIDEC sampled approximately\n232 private drinking water wells for PFOA contamination, and of these wells, approximately 126\nwells showed levels of PFOA contamination above the VHAL of 20 ppt.\n\n202. By mid-April 2017, the VITDEC had sampled approximately 570 private drinking\n\nwater wells for PFOA contamination, and of these wells, 276 showed levels of PFOA\n\n44\n\f2:26-cv-00291-kjd Document1 Filed 08/25/26 Page 45 of 69\n\ncontamination above the VHAL of 20 ppt.\n\n203. On April 13, 2016, the Vermont Agency of Natural Resources (\"ANR\"), based on\nits findings that PFOA is toxic, persistent in the environment, causes and contributes to adverse\nchronic health effects, and is a suspected carcinogen, adopted an emergency rule classifying\nPFOA as a hazardous waste under Vermont Hazardous Waste Management regulations. The\nrule became permanent in December 2016.\n\n204. In late April 2016, the DOH, in conjunction with the Centers for Disease Control\n(\"CDC\"), as part of the State's response to the PFOA contamination of private drinking water\nwells, began to fund blood testing of North Bennington and Bennington residents whose drinking\nwater wells have shown the presence of elevated levels of PFOA.\n\n205. %In2016, aclass action lawsuit was filed in this Court, Sullivan et al. v. Saint-\nGobain Performance Plastics Corp., No. 5:16-cv-00125-gwe, arising from the PFOA\ncontamination discovered in Bennington and North Bennington. That litigation resulted in a Court-\napproved class settlement in 2022, which addressed PFOA contamination identified through 2016\u2014\n2017 sampling. No prior litigation addressed contamination subsequently discovered beginning in\n2023 in the Town of Shaftsbury and in the Town of Bennington outside of the original\n\u201ccontamination area\u201d identified in the Sullivan litigation.\n\n206. In May 2019, the Vermont Legislature enacted a law that required statewide\nsampling and monitoring for PFAS contamination. Pursuant to this law, in June 2019, Vermont\nissued a PFAS Statewide Sampling Plan.\n\n207. In 2023, the VTDEC began well testing in areas around Shaftsbury and southern\nBennington as part of the sampling of 500 randomly selected private wells throughout Vermont.\n\nThis sampling indicated the presence of PFOA in several private drinking water wells, which\n\n45\n\f2:26-cv-00291-kjd Document1 Filed 08/25/26 Page 46 of 69\n\nprompted the VTDEC to perform confirmatory sampling, and install POETs on impacted wells.\n\n208. Between late 2023 and 2025, follow-up sampling was performed to further\ncharacterize the zone of PFOA contamination. It showed extensive contamination in Shaftsbury\nand southeastern Bennington outside the contamination area designated in the certification of the\nSettlement Class in Sud/ivan with private wells in excess of 20-70 ppt of PFOA, many times the\nState and Federal allowable limit of 4 ppt.\n\n209. A 2025 Bennington College Community Research Report examining the\nVTDEC\u2019s water sample dataset from 698 individual private wells in the region revealed\nincreased levels of PFOA between 2016 and 2024, indicating that contamination is increasing\nover time.\n\n210. On March 25, 2025, the VIDEC wrote to Defendant SGPP identifying it as a\nresponsible party for the recently discovered contamination in Shaftsbury and southern\nBennington in the \u201c2025 Areas of Concern\u201d and outlining future testing and corrective actions\nneeded to address the contamination.\n\n211. Plaintiffs and Class Members whose wells have been contaminated with PFOA\nabove the 2026 Vermont Groundwater Protection Limit of 4 ppt have been advised not to use\ntheir well water for drinking or cooking purposes and are forced to rely on bottled water and\nfiltration systems.\n\n212. Plaintiffs and Class Members whose private drinking water wells have been\ncontaminated with PFOA have also suffered soil contamination in addition to the ground water\ncontamination on their property.\n\n213. Asaresult of the ground water and soil contamination, Plaintiffs and Class\n\nMembers have suffered diminution of property value.\n\n46\n\f2:26-cv-00291-kjd Document1 Filed 08/25/26 Page 47 of 69\n\n214. As aresult of the ground water contamination, Plaintiffs and Class Members have\nbeen required to use bottled water and/or Point of Entry Treatment Systems and have suffered\nannoyance, upset, and aggravation and inconvenience.\n\n215. Asaresult of the contamination of their private drinking water supply wells with\nPFOA, Plaintiffs and Class Members have consumed and ingested PFOA over many years, with\ndeleterious long-term physiologic alterations and damage to their blood, liver, kidneys, immune\nsystem, and other organs.\n\n216. The allegations in this complaint arise exclusively from PFOA emissions and\ndischarges from the SGPP Facilities\u2019 AFD coating operations.\n\nCLASS ACTION ALLEGATIONS\n\n217. Plaintiffs incorporate the foregoing paragraphs as though the same were set forth\nat length herein.\n\n218. Plaintiffs bring this action pursuant to the provisions of Rule 23(a), 23(b)(2), and\n(b)(3) of the Federal Rules of Civil Procedure as a class action on their own behalf and on behalf\nof other persons similarly situated. This action satisfies the numerosity, commonality, typicality,\npredominance, and superiority requirements of Fed. R. Civ. P. 23(a) and 23(b).\n\n219. Plaintiffs bring this class action on behalf of the following classes, as set forth\nbelow:\n\na. Property Devaluation and Groundwater Protection Act Class for\nDrinking Water Contamination\n\nAll individuals who are or were owners of real property located in the Town of Shaftsbury\nand/or Town of Bennington that was supplied with drinking water from a private well\ncontaminated with PFOA, who owned that property at the time the contamination of the property\u2019s\nprivate well was discovered whose property value has been reduced due to the presence of PFOA\n\nin their drinking water;\n\nb. Property Devaluation Class for Soil Contamination\nAll individuals who are or were owners of real property located in the Town of Shaftsbury\n\n47\n\f2:26-cv-00291-kjd Document1 Filed 08/25/26 Page 48 of 69\n\nand/or Town of Bennington that was contaminated with PFOA without contamination yet being\ndiscovered in the drinking water of such property, who owned that property at the time this lawsuit\nwas commenced;\nc. Nuisance\nAll individuals who resided at real property located in the Town of Shaftsbury and/or Town\nof Bennington that was supplied with drinking water from a private well contaminated with PFOA,\nand who resided at that property at the time the contamination of the property\u2019s private well was\ndiscovered through a water test.\nd. Medical Monitoring Class\nAll individuals who resided and ingested tap water for at least six months at a property\nlocated in the Town of Shaftsbury and/or Town of Bennington that was supplied with drinking\nwater from a private well contaminated with PFOA, and who have suffered an accumulation of\nPFOA in the bodies as demonstrated by blood serum tests disclosing a PFOA level in their blood\nat or above 2.00 ug/L; or any natural child birthed by an individual who meets and/or met this\n\ncriteria at the time of the child\u2019s birth and whose blood serum was tested after birth disclosing a\nPFOA level at or above 2.0 ug/L.\n\n220. Excluded from the Classes are:\n\na. Defendants and any entities in which a Defendant has a controlling interest,\nand their legal representatives, officers, directors, successors, or assigns;\n\nb. The Judge to whom this case is assigned and the Judge\u2019s staff;\n\nc. Any attorneys, or their immediate family, representing Plaintiffs or\nMembers of the proposed Class;\n\nd. Any State or any of its agencies;\n\ne. The Town of Shaftsbury;\n\nf. The Town of Bennington;\n\ng. The Village of North Bennington;\n\nh. All persons who otherwise would be included under one or more of the\nclass descriptions, but who have filed a lawsuit for manifest personal injury\nfor PFOA-related illness related to exposure to contaminated water;\n\ni. All persons who qualified for benefits under the Class Action Settlement\n\n48\n\f2:26-cv-00291-kjd Document1 Filed 08/25/26 Page 49 of 69\n\nin Sullivan v. Saint-Gobain, Case No. 5:16-cv-00125-gwe (D. Vt. Apr. 18,\n2022) (ECF 481) (Final Order of Approval).\n\nj. All persons or entities that properly execute and timely file a request for\nexclusion from the Class;\n\n221. Plaintiffs reserve the right to amend the Class definitions set forth above if, prior\nto the Court\u2019s determination on whether certification is appropriate, discovery and/or further\ninvestigation reveals that any Class should be expanded, divided into subclasses, or modified in\nany way.\n\nNumerosity\n\n222. Although the exact number of class members is uncertain and can be ascertained\nonly through appropriate discovery, the number is great enough such that joinder is\nimpracticable. Indeed, there are approximately 250 private wells in the Town of Shaftsbury and\nmany more private wells in the Town of Bennington whose owners were ineligible for benefits\nunder the Sullivan Final Order of Approval, and there are hundreds of individuals who resided at\nproperties utilizing such wells for drinking water and who have consumed contaminated drinking\nwater. Since 2023, approximately 25 wells in Shaftsbury and 100 wells in southern Bennington\nhave tested positive for PFOA. Testing coordinated by the State of Vermont remains ongoing.\nEach of the classes set forth above is sufficiently numerous to warrant class treatment, and the\ndisposition of the claims of these class members in a single action will provide substantial\nbenefits to all parties and to the Court.\n\nTypicality\n223. Plaintiffs\u2019 claims are typical of the claims to be advanced by Members of the\n\nClasses, and their claims encompass those of the other Class Members in each class, in that the\n\n49\n\f2:26-cv-00291-kjd Document1 Filed 08/25/26 Page 50 of 69\n\nfacts and circumstances giving rise to liability are the same, the claims are based on the same\nlegal theories, and the damages suffered by the Plaintiffs are the same kinds of damages suffered\nby the Members of the Classes.\n\n224. Moreover, the factual bases of Defendants\u2019 misconduct are common to all\nMembers of the Classes and represent a common thread of misconduct resulting in injury to all\nmembers of the classes.\n\nAdequate Representation\n\n225. Plaintiffs will fairly and adequately represent and protect the interests of the\nClasses, as their interests do not conflict, their interests are co-extensive with common rights of\nrecovery based on the same essential facts and legal theories, they are members of the same\ncommunities, they are similarly damaged and are seeking the same remedies, and they intend to\nprosecute this action vigorously.\n\n226. Plaintiffs have retained counsel with substantial experience litigating both\nenvironmental torts and class actions, including actions, like this one, representing putative\nclasses whose property has been devalued by the actions of a polluter and/or who have been\nexposed to dangerous chemicals and are in need of biomonitoring, including Sullivan v. Saint-\nGobain, Case No. 5:16-cv-00125-gwe (D. Vt. Apr. 18, 2022) and Baker v. Saint-Gobain\nPerformance Plastics, et al., 16-cv-0917 (N.D.N.Y).\n\nPredominance of Common Questions\n\n227. Plaintiffs bring this action under Rule 23(b)(3) because there are numerous\nquestions of law and fact common to Plaintiffs and the class members that predominate over any\nquestion affecting only individual class members. The answers to these common questions will\n\nadvance resolution of the litigation as to all class members. These common legal and factual\n\n50\n\f2:26-cv-00291-kjd Document1- Filed 08/25/26 Page 51 of 69\n\nissues include:\n\nWhether Defendant SGPP owed a duty to Plaintiffs and members of the\nclasses to refrain from conduct reasonably likely to cause contamination\nof class members\u2019 drinking water;\n\nWhether Defendant SGPP knew or should have known that it was\nunreasonably dangerous to release PFOA into the environment during its\noperation of fabric coating facilities in North Bennington, Vermont;\nWhether Defendant SGPP knew or should have known that releasing\nPFOA in the manner alleged herein was reasonably likely to cause\ncontamination of class members\u2019 properties and drinking water;\nWhether Defendant SGPP breached a legal duty to Plaintiffs and the\nclasses by releasing PFOA in the manner described herein;\n\nWhether Defendant SGPP\u2019s breach of a legal duty caused class members\u2019\nproperties and drinking water to become contaminated with PFOA;\nWhether it was foreseeable that Defendant SGPP\u2019s use of PFOA would\ncause class members\u2019 properties and drinking water to become\ncontaminated;\n\nWhether Defendant SGPP owed a duty to Plaintiffs and Members of the\nClass to prevent and/or minimize any discharge or release of PFOA into\nthe surrounding environment;\n\nWhether Defendant SGPP knew or should reasonably have known that\nthe failure to have policies or procedures regarding the proper handling,\n\ncleanup, or disposal of PFOA would result in contamination to\n\n51\n\f2:26-cv-00291-kjd Document1 - Filed 08/25/26 Page 52 of 69\n\ngroundwater and soil and cause damages to Plaintiffs and Members of the\nClass;\n\ni. Whether it was reasonably foreseeable to Defendant SGPP that the\ndischarge or release of PFOA into the environment would result in\ncontamination of groundwater and soil and cause damages to Plaintiffs\nand Members of the Class;\n\nj. Whether Defendant SGPP should have advised residents and state and\nlocal authorities that soil and drinking water in the Towns of Shaftsbury\nand Bennington was likely contaminated with PFOA after testing by Barr\nEngineering as part of the Processors Mass Balance Study of fabric-\ncoating ovens in Merrimack, New Hampshire identical to those used by\nSGPP in North Bennington prior to the closing of these facilities\ndefinitively demonstrated that coating fabric and other substates with\nAFD in such ovens released PFOA into the air;\n\nk. Whether Defendants DuPont and 3M knew or should have known that\ntheir PFOA and PFOA-containing products posed a risk to the\nenvironment and health of people living in or near the communities\nwhere these products were used, such as the Towns of Shaftsbury and\nBennington;\n\n|. Whether Defendants DuPont and 3M failed to adequately warn of the\nhealth and environmental hazards potentially caused by the anticipated\nuse of their PFOA-containing products, specifically the heating of AFD\n\nto a temperature sufficient to cause sublimation of APFO into PFOA\n\n52\n\f2:26-cv-00291-kjd Document1 Filed 08/25/26 Page 53 of 69\n\nvapor but insufficient to cause a decarboxylation of such PFOA\nmolecules resulting in their release into the environment;\n\nm. Whether Defendants DuPont and 3M failed to provide adequate\ninstructions regarding technologies that could reduce or eliminate the\nPFOA emissions for AFD coating manufacturing facilities and/or that\nPFOA could be replaced in AFD dispersions with another surfactant.\n\nn. Whether Defendants DuPont and 3M breached their continuing duty to\nwarn of dangers of their products discovered after manufacture and sale;\n\no. Whether Plaintiffs and the classes are at increased risk of illness and\nharm as a result of the PFOA accumulation they have sustained in their\nbodies as a result of drinking and cooking with PFOA contaminated\nprivate well water;\n\np. Whether biomonitoring and surveillance is reasonable and necessary to\nassure early diagnosis and treatment of PFOA-related illnesses and\nconditions;\n\nq. Whether early diagnosis and treatment of the conditions caused by PFOA\nwill be beneficial to Plaintiffs and the Medical Monitoring Class;\n\nr. Whether Defendants\u2019 contamination of the groundwater in the Towns of\nShaftsbury and Bennington with toxic PFOA constitutes unreasonable\nharm to groundwater through the alteration of its character or quality in\nviolation of Vermont\u2019s Groundwater Protection Act, 10 V.S.A. \u00a7\n1410(c); and\n\ns. Whether the contamination of the drinking water and/or soil of the\n\n53\n\f2:26-cv-00291-kjd Document1 Filed 08/25/26 Page 54 of 69\n\nproperties owned by the class members caused a reduction in their resale\nvalue;\n\nt. Whether Defendants\u2019 conduct was intentional, reckless or grossly\nnegligent warranting the imposition of punitive damages.\n\n228. Plaintiffs and members of the classes have all suffered and will continue to suffer\nharm and damages as a result of Defendants\u2019 unlawful and wrongful conduct. A class action is\nsuperior to the other available methods for the fair and efficient adjudication of this controversy.\n\n229. Absent a class action the cost of litigating their individual class member\u2019s claims\nwould be prohibitively high and, therefore, deprive them of any effective remedy at law.\nFurther, without class litigation, class members will continue to incur damages.\n\n230. Class treatment of common questions of law and fact will conserve the resources\nof the courts and the litigants, and will promote consistency and efficiency of adjudication.\n\nFed. R. Civ. P_23(a) and 23(b)(2) Injunctive or Declaratory Relief\n\n231. In addition to the above, Plaintiffs bring this Class action under Fed. R. Civ. P.\n23(a) and 23(b)(2), because Defendants have acted or refused to act on grounds that apply\ngenerally to the Classes, such that final injunctive relief or declaratory relief is appropriate with\nrespect to each Class as a whole. Such injunctive relief includes, but is not limited to, an\ninjunction to require a medical monitoring program sufficient to monitor class members\u2019 health\nto ensure they are adequately protected from the deleterious effects and potentially-deleterious of\nPFOA on the human body and to detect and remedy these effects to the extent possible, and\nequitable relief pursuant to the Vermont Groundwater Protection Act, 10 V.S.A. \u00a7 1410(c).\n\n232. Accordingly, Plaintiffs seek an injunction requiring the Defendants to implement\n\n54\n\f2:26-cv-00291-kjd Document1 Filed 08/25/26 Page 55 of 69\n\na medical monitoring program to aid the Medical Monitoring Class pursuant to 12 V.S.A. \u00a7\n7202;\n\n233. Finally, the Plaintiffs and the class seek a declaration that Defendants acted with\nnegligence, gross negligence, and/or willful, wanton, and careless disregard for the health and\nsafety of the lives of Plaintiffs and members of the class.\n\nFed. R. Civ. P. 23(a) and 23(c)(4) Certification of Particular Issues\n\n234. In the alternative to certification under Rule 23(b)(2) or 23(b)(3), Plaintiffs and\nthe classes seek to maintain a class action with respect to particular issues under Rule 23(c)(4).\n\n235. Specifically, Defendants\u2019 liability is suitable for issue certification under Rule\n23(c)(4).\n\nCAUSES OF ACTION\n\nCOUNT I: NEGLIGENCE\n\n236. Plaintiffs hereby incorporate by reference the allegations contained in the\npreceding paragraph of this Complaint as if they were set forth at length herein.\n\n237. Defendants knew or should have known that PFOA-containing AFD that were\nused in the manufacturing processes at Defendant SGPP\u2019s Facilities would result in the release\ninto the environment of PFOA, the contamination of soil and groundwater, ingestion of that\ngroundwater by the communities of Shaftsbury and Bennington, accumulation of PFOA in the\nbodies of members of those communities, including Plaintiffs, and potential adverse health\neffects to those people, including Plaintiffs.\n\n238. Defendants knew or should have known that use of PFOA, PFOA-containing\nAFD dispersions and/or the discharge of PFOA into the air, ground, and sewer system was\n\npotentially hazardous to human health and the environment and required Defendants to take\n\n55\n\f2:26-cv-00291-kjd Document1 Filed 08/25/26 Page 56 of 69\n\nadequate safety precautions to ensure that PFOA was not released into the surrounding\nenvironment.\n\n239. Defendants further knew or should have known that it was unsafe and/or\nunreasonably dangerous to wash out and/or discharge into the environment the AFD residue\nfrom the manufacturing equipment where PFOA-containing AFD was used.\n\n240. Defendants further knew or should have known that it was unsafe and/or\nunreasonably dangerous to permit PFOA vapor and particulate matter to exit from stacks at the\nfacility without adequate control measures.\n\n241. During some of the years of operation of the Defendant SGPP Facilities,\ndefendants 3M and DuPont failed to share information and knowledge that these companies had\nand to provide adequate warnings and instructions to Defendant SGPP about the hazards of\nPFOA to the environment and to the safety of the community.\n\n242. At some point in time after the use of PFOA and PFOA-containing AFD at\nDefendant SGPP\u2019s Facilities began, either based upon information provided by defendants 3M\nand DuPont, through the testing done by Barr Engineering at SGPP\u2019s Merrimack Facility, or\nthrough published and available literature, Defendant SGPP knew or should have known of the\nenvironmental risks and health hazards associated with exposure of human beings to PFOA.\n\n243. Defendants 3M and DuPont had a continuing duty to warn purchasers of their\nPFOA and PFOA-containing products of risks and hazards learned by such defendants after sale\nof these products.\n\n244. Defendant SGPP had a duty to exercise due and reasonable care in its use,\nhandling, disposal and discharge of PFOA and PFOA-containing PTFE dispersions to prevent or\n\nminimize any discharge or release of PFOA into the surrounding environment, including into the\n\n56\n\f2:26-cv-00291-kjd Document1 Filed 08/25/26 Page 57 of 69\n\nair, soils, groundwater.\n\n245. Defendant SGPP knew or reasonably should have known that the use of PFOA in\nits manufacturing processes and/or the discharge or release of PFOA into the environment\nrequired adequate safety precautions to ensure that PFOA was not released into the surrounding\nenvironment.\n\n246. Defendant SGPP breached the above-stated duties by unreasonably releasing or\ndisposing of PFOA-containing dispersions and/or releasing PFOA in a manner that guaranteed\nPFOA would enter the environment, including the soil and groundwater, and be ingested by\nresidents, including Plaintiffs.\n\n247. Defendants 3M and DuPont had a duty to warn users of their PFOA products of\nthe dangers of releasing PFOA into the environment and breached that duty by failing to disclose\ninformation they possessed about the health hazards associated with PFOA exposure, the\npropensity of PFOA to cause environmental contamination of soil and drinking water, and the\nbioaccumulation of PFOA in people ingesting such contaminated drinking water.\n\n248. Defendants 3M and DuPont further breached their continuing duties to warn\nabout the dangers of PFOA learned after the manufacture and sale of their PFOA and PFOA-\ncontaining products to Defendant SGPP.\n\n249. Defendants 3M and DuPont breached the above-stated duties by failing to\nadequately warn and provide sufficient instructions to foreseeable users of the products including\nemployees handling and disposing of the products at Defendant SGPP\u2019s Facilities, and to avoid\ndischarging PFOA into the environment where it was likely to enter the soil and groundwater\nand be ingested by residents such as plaintiffs.\n\n250. Had Defendants DuPont and 3M provided adequate warnings and instructions of\n\n57\n\f2:26-cv-00291-kjd Document1 Filed 08/25/26 Page 58 of 69\n\nthe known health hazards and risk of environmental contamination of PFOA and their PFOA-\ncontaining products to purchasers, users, governmental agencies, and the public, it is more likely\nthan not that Plaintiffs\u2019 injuries and damages would not have occurred or would have been\nlessened as actions would have been taken to reduce or eliminate Plaintiffs\u2019 exposure to PFOA\nbefore toxic accumulation in the body and environment occurred.\n\n251. Defendant SGPP also breached its duty to advise residents and state and local\nauthorities of the likelihood that soil and drinking water in the Town of Shaftsbury and Town of\nBennington was likely to be contaminated with PFOA after testing of fabric-coating ovens in\nMerrimack, New Hampshire identical to those used by Defendant SGPP in Bennington and\nNorth Bennington prior to the closing of these facilities in 2003 by Barr Engineering definitively\ndemonstrated that such ovens released PFOA into the air.\n\n252.  Asaresult of Defendants\u2019 breaches of the various duties set forth above, the soil\nand drinking water in and around Shaftsbury and Bennington became contaminated with unsafe\nlevels of PFOA, which was ingested by Plaintiffs.\n\n253. Upon information and belief, Defendants 3M and DuPont were grossly negligent,\nacted with reckless indifference to the health and safety of the public and/or intentionally failed\nto make public or provide to purchasers of their products information these defendants possessed\nabout the potential danger and harm that accumulation of PFOA in the human beings resulting\nfrom discharge of PFOA into the environment could cause.\n\n254. Upon information and belief, Defendant SGPP was grossly negligent, acted with\nreckless indifference to the health and safety of the public, and/or intentionally failed to prevent\nPFOA from being discharged into the environment and in failing to inform the public in general\n\nof the potential that PFOA was contaminating its private water supply.\n\n58\n\f2:26-cv-00291-kjd Document1 - Filed 08/25/26 Page 59 of 69\n\n255. Asa direct and proximate result of Defendants' conduct described herein, PFOA\nwas deposited in soil and groundwater in the Towns of Shaftsbury and Bennington,\ncontaminating soil and private drinking water wells, including those of Plaintiffs and Class\nMembers, above the applicable state and federal levels.\n\n256. Asa direct and proximate result of Defendants\u2019 actions and omissions described\nherein, Plaintiffs have suffered injuries to person and property caused by the release of PFOA\ninto the environment, contamination of soil and groundwater, and accumulation of PFOA into\ntheir bodies, entitling them to compensatory and consequential damages, including the cost of\nfuture medical monitoring.\n\nCOUNT II: PRIVATE NUISANCE\n\n257. Plaintiffs hereby incorporate by reference the allegations contained in the\npreceding paragraphs of this Complaint as if they were set forth herein.\n\n258. Defendants\u2019 intentional acts and omissions relating to its use, handling, discharge,\nand/or disposal of PFOA, has contaminated Plaintiffs\u2019 and Class Members\u2019 properties and/or\nprivate drinking water supply wells with PFOA, thereby unreasonably and substantially\ninterfering with Plaintiffs\u2019 and Class Members\u2019 property rights, privileges, and use and\nenjoyment of property so as to constitute a private nuisance.\n\n259. Asa direct and proximate result of Defendants\u2019 creation and maintenance of a\nprivate nuisance, Plaintiffs and Class Members have suffered damages in the form of real\nproperty damage, out-of-pocket expenses, personal property damage, loss of use and enjoyment\nof property, diminution in property value, the necessity for long-term medical monitoring,\nannoyance, upset, aggravation and inconvenience, for which Defendant Saint-Gobain is liable in\n\ndamages and equitable relief, including but not limited to, injunctive relief requiring abatement\n\n39\n\f2:26-cv-00291-kjd Document1 Filed 08/25/26 Page 60 of 69\n\nof the nuisance through remediation of contaminated groundwater and soils.\n\nCOUNT III: TRESPASS AGAINST DEFENDANT SGPP\n\n260. Plaintiffs hereby incorporate by reference the allegations contained in the\npreceding paragraphs of this Complaint as if they were set forth herein.\n\n261. Defendant SGPP\u2019s intentional acts or omissions in its use handling, discharge\nand/or disposal of PFOA and PFOA-containing AFD has proximately caused PFOA to enter\nonto the property of the Plaintiffs and Class Members, resulting in the contamination of\nPlaintiffs\u2019 and Class Members\u2019 premises, thereby affecting Plaintiffs\u2019 and Class Members\u2019\ninterest in the exclusive possession of their property.\n\n262. Defendant SGPP knew or had substantial certainty that its acts or omissions\nalleged herein could result in PFOA entering and remaining on Plaintiffs\u2019 and Class Members\u2019\nproperties.\n\n263. Asa direct and proximate result of Defendant SGPP\u2019s trespass, Plaintiffs and\nClass Members have suffered damages in the form of real property damage, out-of-pocket\nexpenses, personal property damage, loss of use of enjoyment of property, diminution in\nproperty value, the necessity for long-term medical monitoring, annoyance, upset, aggravation,\nand inconvenience, for which Defendant SGPP is liable in damages.\n\nCOUNT IV: STRICT PRODUCTS LIABILITY\u2014FAILURE TO WARN AGAINST\nDEFENDANTS DUPONT AND 3M\n\n264. Plaintiffs hereby incorporate by reference the allegations contained in the\npreceding paragraphs of this Complaint as if they were set forth herein.\n\n265. From the 1950s through approximately 2000, Defendant 3M developed, tested,\nassembled, manufactured, packaged, labeled, prepared, distributed, marketed, and/or supplied for\n\nsale and sold APFO to Defendant DuPont, to other manufacturers of AFD, and directly to\n\n60\n\f2:26-cv-00291-kjd Document1 Filed 08/25/26 Page 61 of 69\n\nDefendant SGPP in the ordinary course of their business.\n\n266. From the 1950s through 2002, Defendant DuPont developed, tested, assembled,\nmanufactured, packaged, labeled, prepared, distributed, marketed, and/or supplied for sale and\nsold AFD containing APFO to Defendant SGPP in the ordinary course of their business.\n\n267. By at least 1984, Defendants DuPont and 3M were aware of the health hazards\nassociated with PFOA exposure as well as the potential for PFOA to contaminate soil and\ndrinking water. Both defendants were also aware that there were technologies that could reduce\nor eliminate the PFOA emissions for AFD coating manufacturing facilities and/or that PFOA\ncould be replaced in AFD with another surfactant. Both Defendants DuPont and 3M chose to\ncontinue to sell APFO and APFO-containing dispersions without advising purchasers that\nprocessing AFD containing APFO would release PFOA into the air, of the true hazards of PFOA\nto human health and the environment or instruct them about and recommend emission reducing\ntechnologies because of concerns for loss of profits to these Defendants.\n\n268. Upon information and belief, Defendant SGPP utilized the APFO and APFO-\ncontaining AFD products supplied by defendants DuPont and 3M in a reasonably foreseeable\nand intended manner for such products\u2019 intended use.\n\n269. The APFO and APFO-containing AFD products sold by Defendants DuPont and\n3M to Defendant SGPP were unreasonably dangerous to residents living in the communities near\nthe SGPP Facilities, including Plaintiffs, without adequate warnings and instructions to prevent\ndischarge of PFOA into the environment contamination of the soil and groundwater, and toxic\naccumulation inside of the bodies of residents, including Plaintiffs.\n\n270. Defendants DuPont and 3M knew or should have known that the APFO and\n\nAPFO-containing AFD products they sold to Defendant SGPP would result in the into the\n\n61\n\f2:26-cv-00291-kjd Document1 Filed 08/25/26 Page 62 of 69\n\nenvironment of PFOA and cause contamination of the soil and water supply and toxic\naccumulation of PFOA in the blood serum of residents living in the communities where their\nproducts were used, including Plaintiffs.\n\n271. Defendants DuPont and 3M had actual knowledge of the health hazards\nassociated with PFOA ingestion through both animal studies conducted by researchers and\ncontractors they employed and through experience with their own workers, but, upon\ninformation and belief, failed to communicate such information to relevant governmental\nagencies, or to foreseeable users of the materials, including employees handling and disposing of\nthem at the SGPP Facilities.\n\n272. Defendants DuPont and 3M also failed to warn and alert purchasers and users or\nthe public of their discoveries of extensive soil and groundwater contamination in communities\nnear their Washington Works (DuPont) and Cottage Grove (3M) facilities once these water\nsupplies were determined to be contaminated with PFOA or other similar fluorochemicals\nproduced by 3M.\n\n273. Defendants DuPont and 3M failed to provide adequate instructions and warnings\nwhen their APFO and APFO-containing products were sold and accordingly sold such products\nthat were unreasonably dangerous for their intended use and defective making them strictly\nliable for the injuries and damages sustained by Plaintiffs.\n\n274. Defendants DuPont and 3M breached their continuing duty to warn of defects in\ntheir products after learning of the extensive environmental contamination caused by PFOA in or\nnear their facilities and failing to provide this information to purchasers, users, and others who\ncould be adversely affected. -\n\n275. Had Defendants DuPont and 3M provided adequate warnings and instructions of\n\n62\n\f2:26-cv-00291-kjd Document1 Filed 08/25/26 Page 63 of 69\n\nthe known health hazards and risk of environmental contamination of PFOA released from their\nAPFO-containing products to purchasers, users, governmental agencies and the public, it is more\nlikely than not that Plaintiffs\u2019 injuries and damages would not have occurred or would have been\nlessened as actions would have been taken to reduce or eliminate Plaintiffs\u2019 exposures to PFOA\nand the contamination of the communities around the SGPP Facilities.\n\n276. Defendants DuPont and 3M acted with reckless indifference to the health and\nsafety of workers using their APFO and APFO-containing AFD products and residents in and\nnear the communities where these products were used, including Plaintiffs, by failing to provide\nadequate warnings that use of these products would produce PFOA emissions and of the known\ndangers of PFOA when discharged into the environment and inhaled and ingested by nearby\nresidents, such as Plaintiffs.\n\n277. Asa direct and proximate result of the sale of Defendants DuPont and 3M\u2019s\ndefective APFO and APFO-containing products lacking proper warnings and instructions,\nPlaintiffs have suffered toxic invasions of their bodies, contamination of their properties and\ndrinking water, and other damages, both economic and non-economic.\n\n278. Asa direct and proximate result of the sale of Defendants DuPont and 3M\u2019s\nAPFO and APFO-containing AFD products lacking proper warnings and instructions, Plaintiffs\nare entitled to consequential damages covering the cost of medical monitoring and surveillance\nfor other illnesses that may develop as a result of their exposure to and accumulation of PFOA in\ntheir bodies.\n\nCOUNT V: VIOLATION OF THE VERMONT\nGROUNDWATER PROTECTION ACT (10 V.S.A. \u00a7\u00a7 1390 ef seq. and 1410)\n\n279. Plaintiffs hereby incorporate by reference the allegations contained in the\n\n63\n\f2:26-cv-00291-kjd Document1 - Filed 08/25/26 Page 64 of 69\n\npreceding paragraphs of this Complaint as if they were set forth herein.\n\n280. Pursuant to the Vermont Groundwater Protection Act, 10 V.S.A. \u00a7 1390 et seq.,\n\u201call persons have a right to the beneficial use and enjoyment of groundwater free from\nunreasonable interference with other persons.\u201d 10 V.S.A. \u00a7 1410(a)(4).\n\n281. Defendants\u2019 contamination of the groundwater in Shaftsbury and Bennington with\ntoxic PFOA constitutes unreasonable harm through the alteration of the character or quality of\nthe groundwater in violation of the Groundwater Protection Act, 10 V.S.A \u00a71410(c).\n\n282. Plaintiffs are \u201cpersons\u201d within the meaning of 10 V.S.A. \u00a7 1410(b)(3), and are\npersons who may maintain an action under the Groundwater Protection Act for equitable relief\nand/or recover damages for Defendants\u2019 unreasonable harm to the groundwater in Shaftsbury.\n\n283. Asa direct and proximate result of Defendants\u2019 violation of the Groundwater\nProtection Act, Defendants are also liable to Plaintiffs for equitable relief, including, but not\nlimited remediation and clean-up of the contaminated groundwater. Defendants are also liable to\nPlaintiffs for damages for its unreasonable harm to the groundwater, including damage to the\nwater supply itself.\n\nCOUNT VI: MEDICAL MONITORING PURSUANT TO 12 V.S.A \u00a7 7202\n\n284. Plaintiffs hereby incorporate by reference the allegations contained in the\npreceding paragraphs of this Complaint as if they were set forth herein.\n\n285. PFOA is a \u201cproven toxic substance\u201d as explained in paragraph 45.\n\n286. Defendant SGPP was an owner and operator of a \u201clarge facility\u201d because at all\ntimes relevant herein, the SGPP Facilities employed 10 or more full-time employees and\nengaged in a manufacturing activity that falls within a Standard Industrial Classification code of\n\n20 through 39.\n\n64\n\f2:26-cv-00291-kjd Document1 Filed 08/25/26 Page 65 of 69\n\n287. Defendant SGPP released PFOA from the SGPP Facilities and PFOA entered the\nair, land, surface water, and/or groundwater in and around Shaftsbury and southern Bennington.\n\n288. Defendant SGPP\u2019s tortious conduct as alleged herein, including but not limited to\nnegligence, nuisance, and strict liability, resulted in the release of PFOA into the air, land,\nsurface water, and/or groundwater in and around Shaftsbury and southern Bennington.\n\n289. Plaintiffs were exposed to PFOA as a result of Defendant SGPP\u2019s tortious\nconduct as alleged herein.\n\n290. Defendant 3M was an owner and operator of a \u201clarge facility\u201d because at all times\nrelevant herein, its facilities employed 10 or more full-time employees and engaged in a\nmanufacturing activity that falls within a Standard Industrial Classification code of 20 through\n39.\n\n291. Defendant 3M manufactured APFO, at one or more of its large facilities.\n\n292. Defendant 3M sold APFO to Defendant SGPP for use in its manufacturing\nprocesses at the SGPP Facilities, as described in paragraph 33.\n\n293. Defendant 3M sold APFO to Defendant DuPont which utilized the chemical to\nproduce APFO-containing AFD products which were sold to Defendant SGPP as described in\nparagraph 34.\n\n294. Asaresult of Defendant 3M\u2019s manufacture and sale of APFO to both Defendants\nSGPP and DuPont, Defendant 3M released PFOA from one or more of its large facilities and\nPFOA entered the air, land, surface water, and/or groundwater in and around Shaftsbury and\nsouthern Bennington.\n\n295. Defendant 3M\u2019s tortious conduct as alleged herein, including but not limited to\n\nnegligence, nuisance, and strict liability failure to warn resulted in the release of PFOA into the\n\n65\n\f2:26-cv-00291-kjd Document1 Filed 08/25/26 Page 66 of 69\n\nair, land, surface water, and/or groundwater in and around Shaftsbury and southern Bennington.\n\n296. Plaintiffs were exposed to PFOA as a result of Defendant 3M\u2019s tortious conduct\nas alleged herein.\n\n297. Defendant DuPont was an owner and operator of a \u201clarge facility\u201d because at all\ntimes relevant herein, its facilities employed 10 or more full-time employees and engaged in a\nmanufacturing activity that falls within a Standard Industrial Classification code of 20 through\n39.\n\n298. Defendant DuPont manufactured APFO-containing AFD products, at one or more\nof its large facilities which were sold to Defendant SGPP as outlined in paragraphs 21-22 herein.\n\n299. As aresult of Defendant DuPont\u2019s manufacture and sale of AFD products to\nDefendant SGPP, Defendant DuPont released PFOA from one or more of its large facilities and\nPFOA entered the air, land, surface water, and/or groundwater in and around Shaftsbury and\nsouthern Bennington.\n\n300. Defendant DuPont\u2019s tortious conduct as alleged herein, including but not limited\nto negligence, trespass, nuisance, and strict liability failure to warn resulted in the release of\nPFOA into the air, land, surface water, and/or groundwater in and around Shaftsbury and\nsouthern Bennington\n\n301. Plaintiffs were exposed to PFOA as a result of Defendant DuPont\u2019s tortious\nconduct as alleged herein.\n\n302. Asa proximate result of Plaintiffs\u2019 exposure to PFOA caused by the tortious\nconduct of all Defendants, Plaintiffs have suffered an increased risk of contracting a serious\ndisease, including two forms of cancer.\n\n303. The increased risk makes it medically necessary for Plaintiffs to undergo periodic\n\n66\n\f2:26-cv-00291-kjd Document1 Filed 08/25/26 Page 67 of 69\n\nmedical examinations different from that prescribed for the general population in the absence of\n\nexposure.\n\n304. Medical monitoring procedures for PFOA exist and are reasonable in cost and\n\nsafe to use, such as those recommended by the NASEM Advisory Committee.\n\nRELIEF DEMANDED\n\nWHEREFORE, Plaintiffs and Members of the above proposed Class respectfully request\n\nthis Court to Grant the following relief:\n\n(a) That this case be certified as a Class action as proposed in this Complaint pursuant to\nthe applicable Rules of Civil Procedure;\n\n(b) A declaration that Defendants acted with negligence, gross negligence, and/or willful,\nwanton, and careless disregard for the health, safety, and property of Plaintiffs and\nMembers of the Classes;\n\n(c) Award Plaintiffs and Class Members damages in an amount greater than Five Million\nDollars ($5,000,000) sufficient to compensate them for damage to real property, out\nof pocket expense including unreimbursed expenses associated with obtaining potable\ndrinking water, personal property damage, loss of use and enjoyment of property,\ndiminution in property value, the necessity for long-term medical monitoring,\nannoyance, upset, aggravation, and inconvenience;\n\n(d) Issue an injunction requiring Defendant to: (1) connect each impacted water supply\nwithin the Zone of Contamination onto municipal water; (2) the establishment and\nimplementation of remedial measures sufficient to permanently prevent PFOAs from\nfurther contaminating Plaintiffs' and Class Members' drinking water supplies and/or\n\nproperties; (3) the establishment and implementation of a long-term medical testing\n\n67\n\f2:26-cv-00291-kjd Document1 - Filed 08/25/26 Page 68 of 69\n\nprotocol for Plaintiffs and Class Members to monitor their health and diagnose at an\nearly stage any ailments associated with exposure, inhalation or ingestion of PFOA;\nand ( 4) the establishment of additional steps, to be proven at trial, that are determined\nnecessary to remediate Plaintiffs' and all Class Members\u2019 properties and/or residences\n\nto eliminate the presence of PFOA;\n\n(e) Award appropriate equitable relief and damages for Defendants\u2019 unreasonable harm\nto groundwater pursuant to Vermont Groundwater Protection Act, 10 V.S.A. \u00a7\n1410(c);\n\n(f) Award the cost to fund a court-supervised long-term medical monitoring program\nadministered by one or more appropriate health professionals, including professionals\nwith expertise in exposure to toxic substances or expertise with treating or monitoring\nthe relevant latent disease or diseases pursuant to 12 V.S.A. \u00a7 7202;\n\n(g) Award punitive damages as a result of Defendants\u2019 intentional, grossly negligent and\nreckless disregard for the safety of Plaintiffs and others in their communities;\n\n(h) Award attorney fees and costs and expenses incurred in connection with the litigation\nof this matter; and\n\n(i) Award such other and further relief as this Court may deem just, proper, and\n\nequitable.\n\nJURY DEMAND\n\nPursuant to the Federal Rule of Civil Procedure 38(b), Plaintiffs demand a trial by jury of\n\nany and all issues in this action so triable of right.\n\n68\n\f2:26-cv-00291-kjd Document1 Filed 08/25/26 Page 69 of 69\n\nDated: August 25, 2026 {)\n\nHad F. ene Esq (WT Bar No. 2438)\nAlexander M. Dean, Esq. (VT Bar No. 5839)\nBARR, STERNBERG, MOSS, SILVER &\nMUNSON, P.C.\n\n507 Main Street\n\nBennington, VT 05201\n\nPhone: (802) 442-6341\n\nFax: (802) 442-115]\n\nEmail: dsilver(@;barrstemberg.com\n\nEmail: adean(@barrsternberp.com\n\nStephen G. Schwarz, Esq. (NY Bar No. 2008936)\n(pro hac vice pending)\n\nHadley E. Lundback, Esq. (NY Bar No. 4377875)\n(pro hac vice pending)\n\nTeagan C. Dolan, Esq. (NY Bar No. 6039192)\n(pro hac vice pending)\n\nFARAC] LANGE, LLP\n\n1882 South Winton Road, Suite ]\n\nRochester, NY 14618\n\nPhone: (585) 325-5150\n\nFax: (585) 325-3285\n\nEmail: sschwarz(@-faraci.com\n\nEmail: hadley(@faraci.com\n\nEmail: tdolan@faraci.com\n\nGary A. Davis, Esq. (NC Bar No. 25976)\n(pro hac vice pending)\n\nKeith A. Johnston, Esq. (TN Bar No. 024134)\n(pro hac vice pending)\n\nDAVIS, JOHNSTON & RINGGER, PC\n21 Battery Park Avenue, Suite 206\nAsheville, NC 28801\n\nPhone: (828) 622-0044\n\nFax: (828) 398-0435\n\nEmail: gadavis@enviroattorney.com\nEmail: kjohnston@enviroattomey.com\n\nAttorneys for Plaintiffs\n\n69\n","ocr_status":1,"date_upload":"2026-08-28T10:50:42.494694-07:00","document_number":"1","attachment_number":null,"pacer_doc_id":"18502238305","is_available":true,"is_free_on_pacer":null,"is_sealed":null,"document_type":1,"description":"Complaint","acms_document_guid":""},{"resource_uri":"https://www.courtlistener.com/api/rest/v4/recap-documents/491739567/","id":491739567,"tags":[],"absolute_url":"/docket/74696906/1/1/allard-v-saint-gobain-performance-plastics-corporation/","date_created":"2026-08-28T10:50:38.263962-07:00","date_modified":"2026-08-28T10:50:38.263978-07:00","sha1":"","page_count":1,"file_size":123961,"filepath_local":null,"filepath_ia":"","ia_upload_failure_count":null,"thumbnail":null,"thumbnail_status":0,"plain_text":"","ocr_status":null,"date_upload":null,"document_number":"1","attachment_number":1,"pacer_doc_id":"18502238306","is_available":false,"is_free_on_pacer":null,"is_sealed":null,"document_type":2,"description":"Civil Cover Sheet","acms_document_guid":""}],"date_created":"2026-08-25T11:35:44.572626-07:00","date_modified":"2026-08-27T21:05:03.929743-07:00","date_filed":"2026-08-25","time_filed":"14:14:19","entry_number":1,"recap_sequence_number":"2026-08-25.001","pacer_sequence_number":15,"description":"COMPLAINT (Class Action) and Demand for Jury Trial against Saint-Gobain Performance Plastics Corporation, 3M Company, E.I. DuPont de Nemours and Company, EIDP, Inc., The Chemours Company, Corteva, Inc. filed by Nicole Lebert, Scott Elithorpe, Shawn Legacy, Catherine Bryars, Deborah Swanson, Linda Allard, Gale Elmore, Alfonso Giorgi. (Filing fee $405 receipt number AVTDC-2259347) (Attachments: # 1 Civil Cover Sheet)(Dean, Alexander) Defendant names added on 8/26/2026 (hbc). (Main Document 1 replaced on 8/27/2026) (hbc). 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