1 with the unabated consumption and use of their fossil fuel products, and despite the existence and 2 Defendants’ knowledge of technologies and practices that could have helped to reduce the 3 foreseeable dangers associated with their fossil fuel products, Defendants continued to market and 4 promote heavy fossil fuel use, dramatically increasing the cost of abatement. At all relevant times, 5 Defendants were deeply familiar with opportunities to reduce the use of their fossil fuel products, 6 reduce global CO2 emissions associated therewith, and mitigate the harms associated with the use 7 and consumption of such products. Examples of that recognition include, but are not limited to the 8 following: a. 9 In 1963, Esso (Exxon) obtained multiple patents on technologies for fuel 10 cells, including on the design of a fuel cell and necessary electrodes,135 and 11 on a process for increasing the oxidation of a fuel, specifically methanol, to 12 produce electricity in a fuel cell.136 b. 13 In 1970, Esso (Exxon) obtained a patent for a “low-polluting engine and 14 drive system” that used an interburner and air compressor to reduce 15 pollutant emissions, including CO2 emissions, from gasoline combustion 16 engines (the system also increased the efficiency of the fossil fuel products 17 used in such engines, thereby lowering the amount of fossil fuel product 18 necessary to operate engines equipped with this technology).137 155. 19 Defendants could have made major inroads to mitigate Plaintiff’s injuries through 20 technology by developing and employing technologies to capture and sequester greenhouse gases 21 emissions associated with conventional use of their fossil fuel products. Defendants had 22 knowledge dating at least back to the 1960s, and indeed, internally researched and perfected many 23 such technologies. For instance: 24 25 135 26 27 28 SHER EDLING LLP Patents, Fuel cell and fuel cell electrodes, Exxon Research Engineering Co. (Dec. 31, 1963), https://www.google.com/patents/US3116169. 136 Patents, Direct production of electrical energy from liquid fuels, Exxon Research Engineering Co. (Dec. 3, 1963), https://www.google.com/patents/US3113049. 137 Patents, Low-polluting engine and drive system, Exxon Research Engineering Co. (May 16, 1970), https://www.google.com/patents/US3513929. COMPLAINT 68