3 and nitrous oxide. These increases will enhance the greenhouse effect, resulting on average in an additional warming of the Earth's surface. The main greenhouse gas, water vapour, will increase in response to global warming and further enhance it.96 4 The IPCC reconfirmed these conclusions in a 1992 supplement to 5 the First Assessment Report.97 1 2 e. 6 The United Nations began preparation for the 1992 Earth Summit in Rio de 7 Janeiro, Brazil, a major, newsworthy gathering of 172 world governments, 8 of which 116 sent their heads of state. The Summit resulted in the United 9 Nations Framework Convention on Climate Change (“UNFCCC”), an 10 international environmental treaty providing protocols for future 11 negotiations aimed at “stabiliz[ing] greenhouse gas concentrations in the 12 atmosphere at a level that would prevent dangerous anthropogenic 13 interference with the climate system.”98 115. 14 These world events marked a shift in public discussion of climate change, and the 15 initiation of international efforts to curb anthropogenic greenhouse emissions—developments that 16 had stark implications for, and would have diminished the profitability of, Defendants’ fossil fuel 17 products. 116. 18 But rather than collaborating with the international community by acting to 19 forestall, or at least decrease, their fossil fuel products’ contributions to global warming, increased 20 mean sea surface temperature, marine heatwaves, harmful algal blooms, and marine toxin 21 outbreaks, and consequent injuries to Plaintiff, Defendants embarked on a decades-long campaign 22 designed to maximize continued dependence on their products and undermine national and 23 international efforts to rein in greenhouse gas emissions. 24 25 26 27 28 SHER EDLING LLP IPCC, Climate Change: The IPCC Scientific Assessment, “Policymakers Summary” (1990), http://www.ipcc.ch/ipccreports/far/wg_I/ipcc_far_wg_I_spm.pdf. 97 IPCC, 1992 Supplement to the First Assessment Report (1992), http://www.ipcc.ch/publications_and_data/ publications_ipcc_90_92_assessments_far.shtml. 98 United Nations, United Nations Framework Convention on Climate Change, Article 2 (1992), https://unfccc.int/resource/docs/convkp/conveng.pdf. 96 COMPLAINT 52