129. 1 In 1998, API, on behalf of Defendants, among other fossil fuel companies and 2 organizations supported by fossil fuel corporate grants, developed a Global Climate Science 3 Communications Plan that stated that unless “climate change becomes a non-issue . . . there may 4 be no moment when we can declare victory for our efforts.” Rather, API proclaimed that “[v]ictory 5 will be achieved when . . . average citizens ‘understand’ (recognize) uncertainties in climate 6 science; [and when] recognition of uncertainties becomes part of the ‘conventional wisdom.’”109 7 The multi-million-dollar, multi-year proposed budget included public outreach and the 8 dissemination of educational materials to schools to “begin to erect a barrier against further efforts 9 to impose Kyoto-like measures in the future.”110 130. 10 Soon after, API distributed a memo to its members identifying public agreement on 11 fossil fuel products’ role in climate change as its highest priority issue.111 The memorandum 12 illuminates API’s and Defendants’ concern over the potential regulation of Defendants’ fossil fuel 13 products: “Climate is at the center of the industry’s business interests. Policies limiting carbon 14 emissions reduce petroleum product use. That is why it is API’s highest priority issue and defined 15 as ‘strategic.’”112 Further, the API memo stresses many of the strategies that Defendants 16 individually and collectively utilized to combat the perception of their fossil fuel products as 17 hazardous. These included: a. 18 Influencing the tenor of the climate change “debate” as a means to establish 19 that efforts to reduce greenhouse gas emissions were not necessary to 20 responsibly address climate change; b. 21 Maintaining strong working relationships between government regulators 22 and communications-oriented organizations like the Global Climate 23 Coalition, the Heartland Institute, and other groups carrying Defendants’ 24 25 26 27 28 SHER EDLING LLP 109 Joe Walker, E-mail to Global Climate Science Team, attaching the Draft Global Science Communications Plan (Apr. 3, 1998), https://assets.documentcloud.org/documents/784572/api-global-climate-science-communicationsplan.pdf. 110 Id. 111 Committee on Oversight and Government Reform, Allegations of Political Interference with Government Climate Change Science, page 51 (Mar. 19, 2007), https://ia601904.us.archive.org/25/items/gov.gpo.fdsys.CHRG110hhrg37415/CHRG-110hhrg37415.pdf. 112 Id. COMPLAINT 59