c. 1 ExxonMobil Oil Corporation is wholly-owned subsidiary of Exxon Mobil 2 Corporation that acts on Exxon Mobil Corporation’s behalf and subject to Exxon Mobil 3 Corporation’s control. ExxonMobil Oil Corporation is incorporated in the State of New York with 4 its principal place of business in Irving, Texas. ExxonMobil Oil Corporation is qualified to do 5 business in California. ExxonMobil Oil Corporation was formerly known as, did or does business 6 as, and/or is the successor in liability to Mobil Oil Corporation. d. 7 “Exxon,” as used hereafter, means collectively defendants Exxon Mobil 8 Corporation and ExxonMobil Oil Corporation, and their predecessors, successors, parents, 9 subsidiaries, affiliates, and divisions. e. 10 Exxon consists of numerous divisions and affiliates in all areas of the fossil 11 fuel industry, including exploration for and production of crude oil and natural gas; manufacture 12 of petroleum products; and transportation, marketing, and sale of crude oil, natural gas, and 13 petroleum products. Exxon is also a major manufacturer and marketer of commodity 14 petrochemical products. f. 15 Exxon directs and has directed substantial fossil fuel product-related 16 business to California, and a substantial portion of its fossil fuel products are extracted, refined, 17 transported, traded, distributed, marketed, and/or sold in California. Among other operations, more 18 than 540 Exxon-, Mobil-, or Esso-branded gas stations operate throughout the state, and Exxon 19 owns and operates a petroleum storage and transport facility in the San Ardo Oil Field in San Ardo, 20 Monterey County, California. From 1966 to 2016, Exxon owned and operated an oil refinery in 21 Torrance, Los Angeles County, California. Exxon Co. USA, an Exxon subsidiary, operated a 22 petroleum refinery in Benicia, Solano County, California, from 1968 to 2000. 23 24 25. BP Entities a. BP P.L.C. is a multi-national, vertically integrated energy and 25 petrochemical public limited company, registered in England and Wales with its principal place of 26 business in London, England. BP P.L.C. consists of three main operating segments: (1) exploration 27 28 SHER EDLING LLP COMPLAINT 10