industry’s goals and strategies for engaging in the climate debate in the future.81 It defined a successful industry campaign on climate change in the following language: “Victory Will Be Achieved When … Average citizens ‘understand’ (recognize) uncertainties in climate science; recognition of uncertainties becomes part of the ‘conventional wisdom’”, and “Those promoting the Kyoto treaty on the basis of extant science appear to be out of touch with reality.”82 “Victory Will Be Achieved When … Average citizens ‘understand’ (recognize) uncertainties in climate science; recognition of uncertainties becomes part of the ‘conventional wisdom’ The Oil Industry continued to fund and promote climate misinformation and oppose climate mitigation actions throughout the 2000s and into the current decade. In 2000, ExxonMobil published an op-ed series entitled “Global Climate Change” which summarized the company’s views on the issue. In one of the four op-eds, called “Unsettled Science,” ExxonMobil describes the science as inherently unsettled, questions whether any changes in climate are due to human activities or natural variation, and suggests that uncertainties regarding climate impacts include positive uncertainties – uncertainties about how much crop yields will increase and how much faster forests will grow.83 The op-ed ends saying that, “while some argue that the science debate is settled and governments should focus only on near-term policies—that is empty rhetoric.”84 Documents discovered via Freedom of Information Act requests demonstrate that from 2001 through 2012 Wei-Hock Soon, a scientist at the Smithsonian Institution, received more than $1.2 million from fossil fuel interests to fund research.85 This included ExxonMobil, API, the Charles Koch Foundation, and Southern Company.86 Soon’s research was touted as independent, and the Smithsonian was disallowed from disclosing the identity of the funders without their permission.87 As explained by the Union of Concerned Scientists, “Soon has written about many aspects of climate change but is best known for his work on the role of solar variability, research that has broadly overstated the role the sun plays in climate change and has been largely discredited by his scientific peers …. Outcry from the climate science community over a 2003 paper published by Soon in Climate Research even resulted in the resignation of several of the journal editors and an admission by the journal’s publisher that the paper should not have been accepted.”88 Leaked slides from a 2014 presentation from the Western States Petroleum Association (the successor to the Western Oil and Gas Association) outline the strategy the industry used to oppose climate change reduction efforts in the state of California, which has the second highest greenhouse emissions of any 81 Global Climate Science Communications Action Plan (1998), available at https://insideclimatenews.org/documents/global-climate-science-communications-plan-1998. 82 Id. 83 EXXONMOBIL, GLOBAL CLIMATE CHANGE: THE OP-ED SERIES (2000), available at https://www.documentcloud.org/documents/2805611-2000-Oped-Series-Global-Climate-ChangeExxon.html#document/p5. 84 Id. 85 See MULVEY & SHULMAN, supra note 77, at 14. 86 Id. 87 Id. 88 Id. 14