1 developing and producing crude oil and natural gas globally.”143 158. 2 Likewise, while Shell orchestrated an entire public relations campaign around 3 energy transitions towards net zero emissions, a fine-print disclaimer in its 2016 net-zero pathways 4 report reads: “We have no immediate plans to move to a net-zero emissions portfolio over our 5 investment horizon of 10–20 years.”144 159. 6 BP, appearing to abide by the representations Lord Browne made in his speech 7 described in paragraph 153 above, engaged in a rebranding campaign to convey an air of 8 environmental stewardship and renewable energy to its consumers. This included renouncing its 9 membership in the GCC in 2007, changing its name from “British Petroleum” to “BP” while 10 adopting the slogan “Beyond Petroleum,” and adopting a conspicuously green corporate logo. 11 However, BP’s self-touted “alternative energy” investments during this turnaround included 12 investments in natural gas, a fossil fuel, and in 2007 the company reinvested in Canadian tar sands, 13 a particularly high-carbon source of oil.145 The company ultimately abandoned its wind and solar 14 assets in 2011 and 2013, respectively, and even the “Beyond Petroleum” moniker in 2013.146 160. 15 After posting a $10 billion quarterly profit, Exxon in 2005 stated that “We’re an oil 16 and gas company. In times past, when we tried to get into other businesses, we didn’t do it well. 17 We’d rather re-invest in what we know.”147 161. 18 Even if Defendants did not adopt technological or energy source alternatives that 19 would have reduced use of fossil fuels, reduced global greenhouse gas pollution, and/or mitigated 20 the harms associated with the use and consumption of such products, Defendants could have taken 21 other practical, cost-effective steps to reduce the use of their fossil fuel products, reduce global 22 greenhouse gas pollution associated therewith, and mitigate the harms associated with the use and 23 24 25 26 27 28 SHER EDLING LLP 143 ConocoPhillips Form 10-K, U.S. Securities and Exchange Commission Webpage (Dec. 31, 2012), https://www.sec.gov/Archives/edgar/data/1163165/000119312513065426/d452384d10k.htm. 144 Energy Transitions Towards Net Zero Emissions, Shell (2016), https://drive.google.com/ file/d/0B_L1nw8WLu0Bbi1QWnJRcHlZblE/view (accessed Nov. 6, 2018). 145 Fred Pearce, Greenwash: BP and the Myth of a World ‘Beyond Petroleum’, THE GUARDIAN (Nov. 20, 2008), https://www.theguardian.com/environment/2008/nov/20/fossilfuels-energy. 146 Javier E. David, ‘Beyond Petroleum’ No More? BP Goes Back to Basics, CNBC (Apr. 20, 2013), http://www.cnbc.com/id/100647034. 147 James R. Healy, Alternate Energy Not in Cards at ExxonMobil, USA TODAY (Oct. 28, 2005), https://usatoday30.usatoday.com/money/industries/energy/2005-10-27-oil-invest-usat_x.htm. COMPLAINT 70