1 personnel with the subject.”80 The primer also was “restricted to Exxon personnel and not to be 2 distributed externally.”81 The primer compiled science on climate change available at the time, and 3 confirmed fossil fuel combustion as a primary anthropogenic contributor to global warming. The 4 report estimated a CO2 doubling around 2090 based on Exxon’s long-range modeled outlook. The 5 author warned that “there are some potentially catastrophic events that must be considered,” 6 including increased sea surface temperatures, and the loss of Antarctic ice sheets. 82 It noted that 7 some scientific groups were concerned “that once the effects are measurable, they might not be 8 reversible.”83 101. 9 In a summary of Exxon’s climate modeling research from 1982, Director of 10 Exxon’s Theoretical and Mathematical Sciences Laboratory Roger Cohen wrote that “the time 11 required for doubling of atmospheric CO2 depends on future world consumption of fossil fuels.” 12 Cohen concluded that Exxon’s own results were “consistent with the published predictions of more 13 complex climate models” and “in accord with the scientific consensus on the effect of increased 14 atmospheric CO2 on climate.”84 102. 15 At the fourth biennial Maurice Ewing Symposium at the Lamont-Doherty 16 Geophysical Observatory in October 1982, attended by members of API, Exxon Research and 17 Engineering Company president E.E. David delivered a speech titled: “Inventing the Future: 18 Energy and the CO2 ‘Greenhouse Effect.’”85 His remarks included the following statement: “[F]ew 19 people doubt that the world has entered an energy transition away from dependence upon fossil 20 fuels and toward some mix of renewable resources that will not pose problems of CO2 21 accumulation.” He went on, discussing the human opportunity to address anthropogenic climate 22 change before the point of no return: 23 24 25 26 27 28 SHER EDLING LLP M. B. Glaser, Exxon Memo to Management about “CO2 ‘Greenhouse’ Effect”, Exxon Research and Engineering Co. (Nov. 12, 1982), http://insideclimatenews.org/sites/default/files/documents/1982%20Exxon%20Primer% 20on%20CO2%20Greenhouse%20Effect.pdf. 81 Id. 82 Id. 83 Id. 84 Cohen, Exxon Memo summarizing findings of research in climate modeling, supra note 77. 85 E. E. David, Jr., Inventing the Future: Energy and the CO2 Greenhouse Effect: Remarks at the Fourth Annual Ewing Symposium, Tenafly, NJ (1982), available at http://sites.agu.org/publications/files/2015/09/ch1.pdf. 80 COMPLAINT 46