1 2 INTRODUCTION 1. The world’s oceans are changing, and commercial fishermen and -women, their 3 businesses, their communities, and their families are paying the price. Climate change is impacting 4 the oceans by increasing average sea temperatures, increasing the frequency and intensity of 5 marine heatwaves, destabilizing and disturbing marine wildlife populations, affecting ocean 6 circulation, and increasing the frequency and severity of harmful algal blooms. These changes 7 threaten both the productivity of commercial fisheries and safety of commercially harvested 8 seafood products. In so doing, they also threaten those that rely on ocean fisheries and ecosystems 9 for their livelihoods, by rendering it at times impossible to ply their trade. With this action, the 10 largest commercial fishing industry trade group on the west coast seeks to hold responsible parties 11 accountable for acute changes to the ocean off of California and Oregon that resulted, over the last 12 three years, in prolonged regulatory closures of the Dungeness crab fisheries—the most lucrative 13 and reliable fisheries on the west coast. Such closures will recur, as the conditions giving rise to 14 them increase in frequency and magnitude as the oceans continue to warm. Accordingly, the crab 15 fishing industry brings this action to force the parties responsible for this severe disruption to 16 fishing opportunity, and the consequent impacts on fishing families, to bear the costs of their 17 conduct. 18 SHER EDLING LLP I. 2. Defendants, major corporate members of the fossil fuel industry, have known for 19 nearly a half century that unrestricted production and use of their fossil fuel products create 20 greenhouse gas pollution that warms the planet, changes our climate, and disrupts the oceans. They 21 have known for decades that those impacts could be catastrophic and that only a narrow window 22 existed to take action before the consequences would be irreversible. They have nevertheless 23 engaged in a coordinated, multi-front effort to conceal and deny their own knowledge of those 24 threats, discredit the growing body of publicly available scientific evidence, and persistently create 25 doubt in the minds of customers, consumers, regulators, the media, journalists, teachers, and the 26 public about the reality and consequences of the impacts of their fossil fuel pollution. At the same 27 time, Defendants have promoted and profited from a massive increase in the extraction and 28 consumption of oil, coal, and natural gas, which has in turn caused an enormous, foreseeable, and COMPLAINT 1