Memorandum for the Petitioners | 61 5.110.Mr. Davies also pointed to possible funding of the Cooler Heads Coalition (CHC), in what he described as “the longest running climate denial coalition.”*“* This was “a coalition of climate denying organizations, funded through the years by respondent ExxonMobil, the Koch Brothers, the Mercers and other ‘dark money,’ who have worked to stall the implementation of effective climate policy since 1997.”2” D.6. From the Kyoto Protocol in 2005 to the Paris Agreement in 2015, the corporate attack on climate science and solutions unabatedly continued 5.111.A 2006 documentary, Who Killed the Electric Car, investigated the efforts of oil companies to limit the development and marketing of electric vehicle technologies. The documentary told the story of new and promising technology for large Nickel Metal Hydride (NiMH) batteries for use in vehicles that was bought by General Motors and, then, respondent Chevron.?*° 5.112.Mr. Muffett explained that the documentary exposed that “Chevron’s arrangement gave the oil company exclusive control of the licensing and use of the NiMH battery patent and alleged that Chevron was using patent entanglement to prevent the further development or use of the technology.” 7°! 5.113.Meanwhile, in his Statement,>* Mr. Davies discussed how the Committee For A Constructive Tomorrow (CFACT) spread misinformation following super typhoon Haiyan.?? 5.113.1. CFACT articulated in a blog that— Typhoon activity in the Philippines is normal. Despite over-the-top reporting before the typhoon struck (timed perfectly for COP 19) Typhoon Haiyan/Yolanda was not the strongest typhoon recorded in the Philippines. It was the seventh. ... There are no worthwhile science or historical records which support the notion that extreme storms have worsened in the Philippines or elsewhere as a result of a warming planet.2>4 248 Davies, K., supra note 223, p. 7. 249 Id. 250 Muffet, C., supra note 141, p. 30. 251 Ibid. 252 Davies, K., supra note 223, p. 7. 253 Id., pp. 8-9. 254 CFACT Ed. (16 November 2013), COP 19: Filipino negotiator goes on hunger strike over typhoon, available at https:/Avww.cfact.org/2013/1 1/16/cop-19-filipino-negotiator-goes-on-hunger-strike-overtyphoon, (last accessed 12 September 2019).