1 5. The rate at which Defendants have extracted and sold fossil fuel products has 2 exploded since the Second World War, as have emissions from those products. The substantial 3 majority of all anthropogenic greenhouse gas emissions in history has occurred since the 1950s, a 4 period known as the “Great Acceleration.”5 About three quarters of all industrial CO2 emissions 5 in history have occurred since the 1960s,6 and more than half have occurred since the late 1980s.7 6 The annual rate of carbon dioxide emissions from production, consumption, and use of fossil fuels 7 has increased by more than 60% since 1990.8 8 6. Defendants have known for nearly 50 years that greenhouse gas pollution from their 9 fossil fuel products has a significant impact on Earth’s climate, including a warming of the oceans. 10 Defendants’ awareness of the negative implications of their own behavior corresponds almost 11 exactly with the Great Acceleration, and with skyrocketing greenhouse gas emissions. With that 12 knowledge, Defendants took steps to protect their own assets from these threats through immense 13 internal investment in research, infrastructure improvements, and plans to exploit new 14 opportunities in a warming world. 15 7. Instead of working to reduce the use and combustion of fossil fuel products, lower 16 the rate of greenhouse gas emissions, minimize the damage associated with continued high use 17 and combustion of such products, and ease the transition to a lower carbon economy, Defendants 18 concealed the dangers, sought to undermine public support for greenhouse gas regulation, and 19 engaged in massive campaigns to promote the ever-increasing use of their products at ever greater 20 volumes. Thus, each Defendant’s conduct has contributed substantially to the buildup of CO2 in 21 the environment that drives ocean warming. 22 23 8. As an actual and proximate consequence of Defendants’ conduct, the crab fishing industry has been deprived of valuable fishing opportunities, and consequently suffered severe 24 25 26 27 28 SHER EDLING LLP and industry remained nearly constant at 9.9 GtC in 2015, distributed among coal (41%), oil (34%), gas (19%), cement (5.6%), and gas flaring (0.7%). Id. at 629. 5 Will Steffen et al., The Trajectory of the Anthropocene: The Great Acceleration, 2 THE ANTHROPOCENE REVIEW 81, 81 (2015). 6 R.J. Andres et al., A synthesis of carbon dioxide emissions from fossil-fuel combustion, 9 BIOGEOSCIENCES, 1845, 1851 (2012). 7 Id. 8 Global Carbon Budget 2016, supra note 4, at 630. COMPLAINT 3