1 collaborate with universities and government to more completely understand what he called the 2 “CO2 problem.”60 3 88. In 1979, API and its members, including Defendants, convened a Task Force to 4 monitor and share cutting edge climate research among the oil industry. The group was initially 5 called the CO2 and Climate Task Force, but changed its name to the Climate and Energy Task 6 Force in 1980 (hereinafter referred to as “API CO2 Task Force”). Membership included senior 7 scientists and engineers from nearly every major U.S. and multinational oil and gas company, 8 including Exxon, Mobil (Exxon), Amoco (BP), Phillips (ConocoPhillips), Texaco (Chevron), 9 Shell, Sunoco, Sohio (BP) as well as Standard Oil of California (BP) and Gulf Oil (Chevron, 10 among others). The Task Force was charged with assessing the implications of emerging science 11 on the petroleum and gas industries and identifying where reductions in greenhouse gas emissions 12 from Defendants’ fossil fuel products could be made.61 89. 13 In 1979, API sent its members a background memo related to the API CO2 and 14 Climate Task Force’s efforts, stating that CO2 concentrations were rising steadily in the 15 atmosphere, and predicting when the first clear effects of climate change might be felt.62 90. 16 Also in 1979, Exxon scientists advocated internally for additional fossil fuel 17 industry-generated research in light of the growing consensus that consumption of fossil fuel 18 products was changing the planet’s climate: “We should determine how Exxon can best participate in all these [atmospheric science research] areas and influence possible legislation on environmental controls. It is important to begin to anticipate the strong intervention of environmental groups and be prepared to respond with reliable and credible data. It behooves [Exxon] to start a very aggressive defensive program in the indicated areas of atmospheric science and climate because there is a good probability that legislation affecting our business will be passed. Clearly, it is in our interest for such legislation to be based on hard scientific data. The data obtained from research 19 20 21 22 23 24 25 60 Id. American Petroleum Institute, AQ-9 Task Force Meeting Minutes (Mar. 18, 1980), http://insideclimatenews.org/ sites/default/files/documents/AQ-9%20Task%20Force%20Meeting%20%281980%29.pdf (AQ-9 refers to the “CO2 and Climate” Task Force). 62 Neela Banerjee, Exxon’s Oil Industry Peers Knew About Climate Dangers in the 1970s, Too, INSIDE CLIMATE NEWS (Dec. 22, 2015), https://insideclimatenews.org/news/22122015/exxon-mobil-oil-industry-peers-knew-about-climatechange-dangers-1970s-american-petroleum-institute-api-shell-chevron-texaco. 61 26 27 28 SHER EDLING LLP COMPLAINT 41