1 respective businesses and a necessary factor in bringing fossil fuel products and their derivatives 2 to the consumer market, such that Defendants had control over, and a substantial ability to 3 influence, the manufacturing and distribution processes of their affiliates and subsidiaries. 4 209. Throughout the time at issue, fossil fuel products have not performed as safely as 5 an ordinary consumer would expect them to because greenhouse gas emissions from their use 6 cause numerous global and local changes to Earth’s climate. In particular, ordinary consumers did 7 not expect that: a. 8 of the industrial revolution, and by far the primary cause of global warming 9 acceleration in the 20th and 21st centuries; 10 11 b. fossil fuel products would cause increase mean sea surface temperature; 12 c. fossil fuel products would cause increased frequency and intensity of marine heatwaves; 13 d. 14 unmitigated use of fossil fuel products causes increased frequency and intensity of harmful algal blooms; 15 e. 16 fossil fuel products cause increased frequency and intensity of marine toxin 17 outbreaks and contamination of natural resources held in the public trust, 18 including Dungeness crabs, necessitating commercial fishery closures and 19 concordant economic injuries; f. 20 the social cost of each ton of CO2 emitted into the atmosphere increases as 21 total global emissions increase, so that unchecked extraction and 22 consumption of fossil fuel products is more harmful and costly than 23 moderated extraction and consumption; and g. 24 for these reasons and others, the unmitigated use of fossil fuel products 25 present significant threats to the environment and human health and 26 welfare, especially to coastal and ocean-dependent communities. 27 28 SHER EDLING LLP fossil fuel products are the primary cause of global warming since the dawn 210. Throughout the times at issue, Defendants individually and in concert widely disseminated marketing materials, refuted the generally accepted scientific knowledge at the time, COMPLAINT 83