117. 1 Defendants’ campaign, which focused on concealing, discrediting, and/or 2 misrepresenting information that tended to support restricting consumption of (and thereby 3 decreasing demand for) Defendants’ fossil fuel products, took several forms. The campaign 4 enabled Defendants to accelerate their business practice of exploiting fossil fuel reserves, and 5 concurrently externalize the social and environmental costs of their fossil fuel products. These 6 activities stood in direct contradiction to Defendants’ own prior recognition that the science of 7 anthropogenic climate change was clear and that the greatest uncertainties involved responsive 8 human behavior, not scientific understanding of the issue. 118. 9 Defendants took affirmative steps to conceal, from Plaintiff and the general public, 10 the foreseeable impacts of the use of their fossil fuel products on Earth’s climate and associated 11 harms to people and communities. Defendants embarked on a concerted public relations campaign 12 to cast doubt on the science connecting global climate change to fossil fuel products and 13 greenhouse gas emissions, in order to influence public perception of the existence of anthropogenic 14 global warming. The effort included promoting their hazardous products through advertising 15 campaigns and the initiation and funding of climate change denialist organizations, designed to 16 influence consumers to continue using Defendants’ fossil fuel products irrespective of those 17 products’ damage to communities and the environment. 119. 18 For example, in 1988, Joseph Carlson, an Exxon public affairs manager, described 19 the “Exxon Position,” which included among others, two important messaging tenets: (1) 20 “[e]mphasize the uncertainty in scientific conclusions regarding the potential enhanced 21 Greenhouse Effect;” and (2) “[r]esist the overstatement and sensationalization [sic] of potential 22 greenhouse effect which could lead to noneconomic development of non-fossil fuel resources.”99 120. 23 A 1994 Shell report entitled “The Enhanced Greenhouse Effect: A Review of the 24 Scientific Aspects” by Royal Dutch Shell environmental advisor Peter Langcake stands in stark 25 contrast to the company’s 1988 report on the same topic. Whereas before, the authors 26 recommended consideration of policy solutions early on, Langcake warned of the potentially 27 28 SHER EDLING LLP Joseph M. Carlson, Exxon Memo on “The Greenhouse Effect” (Aug. 3, 1988), https://assets.documentcloud.org/ documents/3024180/1998-Exxon-Memo-on-the-Greenhouse-Effect.pdf. 99 COMPLAINT 53