1 message minimizing the hazards of the unabated use of their fossil fuel 2 products and opposing regulation thereof; c. 3 Building the case for (and falsely dichotomizing) Defendants’ positive 4 contributions to a “long-term approach” (ostensibly for regulation of their 5 products) as a reason for society to reject short term fossil fuel regulations, 6 and engaging in climate change science uncertainty research; and d. 7 Presenting Defendants’ positions on climate change in domestic and international forums, including by preparing rebuttals to IPCC reports. 8 131. 9 Additionally, Defendants mounted a campaign against regulation of their business 10 practices in order to continue placing their fossil fuel products into the stream of commerce, despite 11 their own knowledge and the growing national and international scientific consensus about the 12 hazards of doing so. These efforts came despite Defendants’ recognition that “risks to nearly every 13 facet of life on Earth . . . could be avoided only if timely steps were taken to address climate 14 change.”113 15 132. The Global Climate Coalition (GCC), on behalf of Defendants and other fossil fuel 16 companies, funded advertising campaigns and distributed material to generate public uncertainty 17 around the climate debate, with the specific purpose of preventing U.S. adoption of the Kyoto 18 Protocol, despite the leading role that the U.S. had played in the Protocol negotiations.114 Despite 19 an internal primer stating that various “contrarian theories” [i.e., climate change skepticism] do 20 not “offer convincing arguments against the conventional model of greenhouse gas emission- 21 induced climate change,” GCC excluded this section from the public version of the backgrounder 22 and instead funded efforts to promote some of those same contrarian theories over subsequent 23 years.115 133. 24 25 A key strategy in Defendants’ efforts to discredit scientific consensus on climate change and the IPCC was to bankroll scientists who, although accredited, held fringe opinions that 26 Banerjee, Exxon’s Oil Industry Peers Knew About Climate Dangers in the 1970s, Too, supra note 60. Id. 115 Gregory J. Dana, Memo to AIAM Technical Committee Re: Global Climate Coalition (GCC) – Primer on Climate Change Science – Final Draft, Association of International Automobile Manufacturers (Jan. 18, 1996), http://www.webcitation.org/6FyqHawb9. 113 27 28 SHER EDLING LLP 114 COMPLAINT 60