c. 1 2 change and greenhouse gas emissions from its fossil fuel products, including those of its 3 subsidiaries. d. 4 Eni Oil & Gas Inc. is incorporated in Texas, with its principal place of 5 business in Houston, Texas. Eni Oil & Gas Inc. is a wholly owned subsidiary of Eni America Ltd., 6 a Delaware corporation doing business in the United States. Eni America, Ltd. is a wholly owned 7 subsidiary of Eni UHL Ltd., a British corporation with its registered office in London, United 8 Kingdom. Eni UHL Ltd. is a wholly owned subsidiary of Eni ULT, Ltd., a British corporation with 9 its registered office on London, United Kingdom. Eni ULT, Ltd. is a wholly owned subsidiary of 10 Eni Lasmo Plc, a British corporation with its registered office on London, United Kingdom. Eni 11 Investments Plc, a British corporation with its registered office in London, United Kingdom, holds 12 a 99.99% ownership interest in Eni Lasmo Plc (the other 0.01% ownership interest is held by 13 another Eni entity, Eni UK Ltd, a British corporation with its registered office in London, United 14 Kingdom). Eni S.p.A owns a 99.99% interest in Eni Investments Plc. Eni UK Ltd. holds the 15 remainder interest in Eni Investments Plc. Collectively, these entities are referred to as “Eni.” e. 16 Eni Oil & Gas Inc. is a successor-in-interest to Golden Eagle Refining 17 Company, Inc. (“Golden Eagle”). At times relevant to this complaint, Golden Eagle did substantial 18 fossil fuel-related business in California. Specifically, Golden Eagle owned and/or operated oil 19 refineries in Carson (Los Angeles County) and Martinez (Contra Costa County), California, and 20 owned and/or operated oil pipelines in or near Long Beach (Los Angeles County), California. 21 22 SHER EDLING LLP Eni controls and has controlled companywide decisions related to climate 31. Anadarko Petroleum Corp. a. Anadarko Petroleum Corporation (“Anadarko”) is incorporated in the State 23 of Delaware and maintains its principal place of business in The Woodlands, Texas. Anadarko is 24 a multinational, vertically integrated energy company comprised of multiple upstream and 25 downstream segments. These include exploration, production, gathering, processing, treating, 26 transporting, marketing, and selling fossil fuel products derived primarily from petroleum and 27 natural gas. In the United States, Anadarko entities operate fossil fuel product exploration and 28 production concerns in Texas, the Gulf of Mexico, Alaska, the Powder River Basin, Utah, COMPLAINT 18