1
c.
Chevron Corporation controls and has controlled companywide decisions
2
related to climate change and greenhouse gas emissions from its fossil fuel products, including
3
those of its subsidiaries.
4
d.
Chevron U.S.A. Inc. is a Pennsylvania Corporation with its principal place
5
of business located in San Ramon, California. Chevron USA is a wholly owned subsidiary of
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Chevron Corporation that acts on Chevron Corporation’s behalf and subject to Chevron
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Corporation’s control. Chevron U.S.A. Inc. was formerly known as, and did or does business as,
8
and/or is the successor in liability to Gulf Oil Corporation, Gulf Oil Corporation of Pennsylvania,
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Chevron Products Company, Chevron Chemical Company, Chevron Energy Solutions Company,
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ChevronTexaco Products Company, Chevron U.S.A. Production Company, and Chevron U.S.A.
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Products Company.
“Chevron” as used hereafter, means collectively, Defendants Chevron
12
e.
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Corp. and Chevron U.S.A. Inc.
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f.
Chevron operates through a web of U.S. and international subsidiaries at all
15
levels of the fossil fuel supply chain. Chevron’s and its subsidiaries’ operations consist of
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exploring for, developing, and producing crude oil and natural gas; processing, liquefaction,
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transportation, and regasification associated with liquefied natural gas; transporting crude oil by
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major international oil export pipelines; transporting, storage, and marketing of natural gas;
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refining crude oil into petroleum products; marketing of crude oil and refined products;
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transporting crude oil and refined products by pipeline, marine vessel, motor equipment and rail
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car; basic and applied research in multiple scientific fields including of chemistry, geology, and
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engineering; and manufacturing and marketing of commodity petrochemicals, plastics for
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industrial uses, and fuel and lubricant additives.
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g.
Chevron directs and has directed substantial fossil fuel-related business to
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California. A substantial portion of Chevron’s fossil fuel products are or have been extracted,
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refined, transported, traded, distributed, marketed, promoted, manufactured, sold, and/or
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consumed in California, from which Chevron derives and has derived substantial revenue.
28
SHER
EDLING LLP
COMPLAINT
8