24. 1 Exxon Entities a. 2 Exxon Mobil Corporation is a multinational, vertically integrated energy 3 and chemicals company incorporated in the State of New Jersey with its headquarters and principal 4 place of business in Irving, Texas. Exxon is among the largest publicly traded international oil and 5 gas companies in the world. Exxon Mobil Corporation was formerly known as, did or does 6 business as, and/or is the successor in liability to ExxonMobil Refining and Supply Company, 7 Exxon Chemical U.S.A., ExxonMobil Chemical Corporation, ExxonMobil Chemical U.S.A., 8 ExxonMobil Refining & Supply Corporation, Exxon Company, U.S.A., Exxon Corporation, and 9 Mobil Corporation. a. 10 Exxon Mobil Corporation controls and has controlled companywide 11 decisions about the quantity and extent of fossil fuel production and sales, including those of its 12 subsidiaries. Exxon Mobil Corporation recently represented that its success, including its “ability 13 to mitigate risk and provide attractive returns to shareholders, depends on [its] ability to 14 successfully manage [its] overall portfolio, including diversification among types and locations of 15 our projects.”9 16 b. Exxon Mobil Corporation controls and has controlled companywide 17 decisions related to climate change and greenhouse gas emissions from its fossil fuel products, 18 including those of its subsidiaries. Exxon Mobil Corporation’s Board, or an individual/sub-set of 19 the Board, or another committee appointed by the Board, holds the highest level of direct 20 responsibility for climate change policy within the company. Exxon Mobil Corporation’s 21 Chairman of the Board and Chief Executive Officer, its President and the other members of its 22 Management Committee are actively engaged in discussions relating to greenhouse gas emissions 23 and the risks of climate change on an ongoing basis. Exxon Mobil Corporation requires its 24 subsidiaries to provide an estimate of greenhouse gas-related emissions costs in their economic 25 projections when seeking funding for capital investments. 26 27 28 SHER EDLING LLP ExxonMobil, “Factors affecting future results” (Feb. 2018), https://cdn.exxonmobil.com/~/media/global/files/investor-reports/2018/2018-factors-affecting-future-results.pdf. 9 COMPLAINT 9