1 and resultant fishery closures have frustrated and will continue to frustrate PCFFA’s mission of 2 ensuring that commercial fishing remains a sustainable livelihood, by damaging markets and 3 preventing trade in crab harvested on the west coast. 4 B. Defendants 5 21. Defendants are responsible for a substantial portion of the total greenhouse gases 6 emitted since 1965. Defendants, individually and collectively, are responsible for extracting, 7 refining, processing, producing, promoting, and marketing fossil fuel products, the normal and 8 intended use of which has led to the emission of a substantial percentage of the total volume of 9 greenhouse gases released into the atmosphere since 1965. Indeed, between 1965 and 2015, the 10 named Defendants extracted enough fossil fuel materials (i.e. crude oil, coal, and natural gas) to 11 account for more than one in every five tons of carbon dioxide and methane emitted worldwide. 12 Accounting in addition for their wholesale and retail sales of products, as well as their wrongful 13 promotion and marketing activities, Defendants bear a dominant responsibility for global warming 14 generally and for Plaintiff’s injuries in particular. 15 22. When reference in this complaint is made to an act or omission of the Defendants, 16 unless specifically attributed or otherwise stated, such references should be interpreted to mean 17 that the officers, directors, agents, employees, or representatives of the Defendants committed or 18 authorized such an act or omission, or failed to adequately supervise or properly control or direct 19 their employees while engaged in the management, direction, operation or control of the affairs of 20 Defendants, and did so while acting within the scope of their employment or agency. 21 22 23. Chevron Entities a. Chevron Corporation is a multinational, vertically integrated energy and 23 chemicals company incorporated in the State of Delaware, with its global headquarters and 24 principal place of business in San Ramon, California. 25 26 b. Chevron Corporation controls and has controlled companywide decisions about the quantity and extent of fossil fuel production and sales, including those of its subsidiaries. 27 28 SHER EDLING LLP COMPLAINT 7