1
and transport, including both petroleum and natural gas products.
e.
2
3
and have controlled their companywide decisions about the quantity and extent of fossil fuel
4
production and sales, including those of their subsidiaries.
f.
5
Marathon Oil Corporation and Marathon Petroleum Corporation control
6
and have controlled their companywide decisions related to climate change and greenhouse gas
7
emissions from its fossil fuel products, including those of its subsidiaries.
g.
8
9
10
Defendants Marathon Oil Company, Marathon Oil Corporation, and
Marathon Petroleum Corporation are collectively referred to as “Marathon.”
35.
Hess Corporation
a.
11
Hess Corporation (“Hess”) is a global, vertically integrated petroleum
12
exploration and extraction company incorporated in the State of Delaware with its headquarters
13
and principal place of business in New York, New York. Hess is registered to do business in
14
California and has designated an agent for service of process in California.
b.
15
16
Hess controls and has controlled companywide decisions about the quantity
and extent of fossil fuel production and sales, including those of its subsidiaries.
c.
17
Hess controls and has controlled companywide decisions related to climate
18
change and greenhouse gas emissions from its fossil fuel products, including those of its
19
subsidiaries.
d.
20
Hess
is
engaged
in
the
exploration,
development,
production,
21
transportation, purchase, marketing, and sale of crude oil and natural gas. Its oil and gas production
22
operations are located primarily in the United States, Denmark, Equatorial Guinea, Malaysia,
23
Thailand, and Norway. Prior to 2014, Hess also conducted extensive retail operations in its own
24
name and through subsidiaries. Hess owned and operated more than 1,000 gas stations throughout
25
the United States, including in California, during times relevant to this complaint. Prior to 2013,
26
Hess also operated oil refineries in the continental United States and U.S. Virgin Islands.
27
28
SHER
EDLING LLP
Marathon Oil Corporation and Marathon Petroleum Corporation control
36.
Devon Energy Entities
a.
Devon Energy Corporation is an independent energy company engaged in
COMPLAINT
22
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