117.
1
Defendants’ campaign, which focused on concealing, discrediting, and/or
2
misrepresenting information that tended to support restricting consumption of (and thereby
3
decreasing demand for) Defendants’ fossil fuel products, took several forms. The campaign
4
enabled Defendants to accelerate their business practice of exploiting fossil fuel reserves, and
5
concurrently externalize the social and environmental costs of their fossil fuel products. These
6
activities stood in direct contradiction to Defendants’ own prior recognition that the science of
7
anthropogenic climate change was clear and that the greatest uncertainties involved responsive
8
human behavior, not scientific understanding of the issue.
118.
9
Defendants took affirmative steps to conceal, from Plaintiff and the general public,
10
the foreseeable impacts of the use of their fossil fuel products on Earth’s climate and associated
11
harms to people and communities. Defendants embarked on a concerted public relations campaign
12
to cast doubt on the science connecting global climate change to fossil fuel products and
13
greenhouse gas emissions, in order to influence public perception of the existence of anthropogenic
14
global warming. The effort included promoting their hazardous products through advertising
15
campaigns and the initiation and funding of climate change denialist organizations, designed to
16
influence consumers to continue using Defendants’ fossil fuel products irrespective of those
17
products’ damage to communities and the environment.
119.
18
For example, in 1988, Joseph Carlson, an Exxon public affairs manager, described
19
the “Exxon Position,” which included among others, two important messaging tenets: (1)
20
“[e]mphasize the uncertainty in scientific conclusions regarding the potential enhanced
21
Greenhouse Effect;” and (2) “[r]esist the overstatement and sensationalization [sic] of potential
22
greenhouse effect which could lead to noneconomic development of non-fossil fuel resources.”99
120.
23
A 1994 Shell report entitled “The Enhanced Greenhouse Effect: A Review of the
24
Scientific Aspects” by Royal Dutch Shell environmental advisor Peter Langcake stands in stark
25
contrast to the company’s 1988 report on the same topic. Whereas before, the authors
26
recommended consideration of policy solutions early on, Langcake warned of the potentially
27
28
SHER
EDLING LLP
Joseph M. Carlson, Exxon Memo on “The Greenhouse Effect” (Aug. 3, 1988), https://assets.documentcloud.org/
documents/3024180/1998-Exxon-Memo-on-the-Greenhouse-Effect.pdf.
99
COMPLAINT
53
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