Memorandum for the Petitioners |141 3. Whether the harm was caused by their actions.%°! 8.208.The above was extensively discussed in this memorandum, pointedly under Part V (D) dealing with Material Facts as Established by Evidence. 8.209.To summarize, the Honorable respondent Carbon Majors have “long their products contribute substantially have significant impacts and adverse vulnerable populations.” Fossil fuel in all aspects of the products Commission should note that known that the production and use of to climate change, which continues to consequences for people, especially companies are presumed to be experts they produced, manufactured, otherwise put into the stream of commerce. marketed, or 8.210.Respondent Carbon Majors did not provide adequate warnings regarding the inherent risks related to the use of their fossil fuel products; thus, failing to enable users to make an informed choice about the use of their products and to understand the potential hazards to which that choice may expose them and others. Additionally, warnings can enable individuals, through their consumption decisions, to push companies to adapt their business model based on consumer demand. 8.211. Based on the evidence presented to the Honorable Commission, fossil fuel industry experts had knowledge of the risks associated with the use of their products and the fact that, collectively, the respondent Carbon Majors were aware that climate change -- primarily caused by the burning of fossil fuels -- posed significant and severe risks to basic human rights, including the right to life, access to food, access to water, and the general right to livelihood, and that respondents have been aware of the risks of climate change and their product’s role in exacerbating those risks since the 1950s or the 1960s, at the latest. 8.212. Instead of enabling consumers to make informed choices on the intrinsic risks with the use of their fossil fuel products, the respondent Carbon Majors did not warn investors, consumers, communities, and the public that there were climate risks associated with the use of fossil fuels and, instead, promoted disinformation and climate denial and sought to delay climate action and solutions. 8.213. Most, if not all, respondents failed to deploy the technologies that may have prevented climate crisis and support action to address climate change in the Philippines or at the global level. $61 Joint Summary of the Amicus Curiae, supra note 50, p. 59. 682 Ibid. 663 Muffett, C., supra note 141.