1 redistribution of harmful algal blooms around the world,39 including Pseudo-nitzschia blooms on 2 the west coast. 3 C. Attribution 4 66. “Carbon factors” analysis, devised by the International Panel on Climate Change 5 (IPCC), the United Nations International Energy Agency, and the U.S. Environmental Protection 6 Agency, quantifies the amount of CO2 emissions attributable to a unit of raw fossil fuel extracted 7 from the ground.40 Emissions factors for oil, coal, liquid natural gas, and natural gas are different 8 for each material but are nevertheless known and quantifiable for each. 41 This analysis accounts 9 for the use of Defendants’ fossil fuel products, including non-combustion purposes that sequester 10 CO2 rather than emit it (e.g., production of asphalt). 11 67. Defendants’ historical and current fossil fuel extraction and production records are 12 publicly available in various fora. These include university and public library collections, company 13 websites, company reports filed with the U.S. Securities and Exchange Commission, company 14 histories, and other sources. The cumulative CO2 and methane emissions attributable to 15 Defendants’ fossil fuel products were calculated by reference to such publicly available 16 documents. 17 68. While it is possible to distinguish CO2 derived from fossil fuels from other sources, 18 it is not possible to determine the source of any particular individual molecule of CO2 in the 19 atmosphere attributable to anthropogenic sources because such greenhouse gas molecules do not 20 bear markers that permit tracing them to their source, and because greenhouse gasses quickly 21 diffuse and comingle in the atmosphere. However, cumulative carbon analysis allows an accurate 22 calculation of net annual CO2 and methane emissions attributable to each Defendant by quantifying 23 the amount and type of fossil fuels products each Defendant extracted and placed into the stream 24 of commerce, and multiplying those quantities by each fossil fuel product’s carbon factor. 25 26 39 27 28 SHER EDLING LLP See Cristopher J. Gobler, et al., Ocean warming since 1982 has expanded the niche of toxic algal blooms in the North Atlantic and North Pacific oceans, Proceedings of the National Academy of Sciences (March 23, 2017). 40 See Richard Heede, Tracing Anthropogenic Carbon Dioxide and Methane Emissions to Fossil Fuel and Cement Producers, 1854–2010, CLIMATIC CHANGE 122, 232–33 (2014). 41 See, e.g., id. COMPLAINT 34