1 business operations in this state, as described above, and because Plaintiff’s injuries described 2 herein arose out of and relate to those operations and occurred in California. 44. 3 4 The Superior Court of California for San Francisco County is a court of general jurisdiction and therefore has subject matter jurisdiction over this action. 45. 5 Venue is proper in San Francisco County pursuant to Code of Civil Procedure 6 section 395.5 because Defendants are corporations and/or associations, and because a substantial 7 portion of the injuries giving rise to Defendants’ liability occurred in San Francisco County. 8 V. FACTUAL BACKGROUND 9 A. Global Land and Ocean Warming—Observed Effects and Known Cause 10 46. Warming of the climate system is unequivocal, and since the 1950s, many of the 11 observed changes to the climate system are unprecedented over decades to millennia. 12 47. The average ocean temperature in 2016 was approximately 1.7° F warmer than the 13 20th-century baseline, which is the greatest positive anomaly observed since at least 1880.15 The 14 increase in hotter temperatures and more frequent positive anomalies during the Great 15 Acceleration is occurring both globally and locally. The graph below shows the increase in global 16 land and ocean temperature anomalies since 1880, as measured against the 1910–2000 global 17 average temperature.16 18 19 20 21 22 23 24 25 26 27 15 28 SHER EDLING LLP NOAA, National Centers for Environmental Information, Climate at a Glance (Global Time Series) (June 2017) https://www.ncdc.noaa.gov/cag/time-series/global/globe/land_ocean/ytd/12/1880-2016. 16 Id. COMPLAINT 27