1 were even more questionable given the sources of their research funding. These scientists obtained 2 part or all of their research budget from Defendants directly or through Defendant-funded 3 organizations like API,116 but they frequently failed to disclose their fossil fuel industry 4 underwriters.117 134. 5 Creating a false sense of disagreement in the scientific community (despite the 6 consensus that its own scientists, experts, and managers had previously acknowledged) has had an 7 evident impact on public opinion. A 2007 Yale University-Gallup poll found that while 71% of 8 Americans personally believed global warming was happening, only 48% believed that there was 9 a consensus among the scientific community, and 40% believed there was a lot of disagreement 10 among scientists over whether global warming was occurring.118 135. 11 2007 was the same year the IPCC published its Fourth Assessment Report, in which 12 it concluded that “there is very high confidence that the net effect of human activities since 1750 13 has been one of warming.”119 The IPCC defined “very high confidence” as at least a 9 out of 10 14 chance.120 136. 15 Defendants borrowed pages out of the playbook of prior denialist campaigns. A 16 “Global Climate Science Team” (“GCST”) was created that mirrored a front group created by the 17 tobacco industry, known as The Advancement of Sound Science Coalition, whose purpose was to 18 sow uncertainty about the fact that cigarette smoke is carcinogenic. The GCST’s membership 19 included Steve Milloy (a key player on the tobacco industry’s front group) for Exxon; an API 20 public relations representative; and representatives from Chevron and Southern Company that 21 drafted API’s 1998 Communications Plan. There were no scientists on the “Global Climate 22 23 24 25 26 27 28 SHER EDLING LLP 116 Willie Soon & Sallie Baliunas, Proxy Climatic and Environmental Changes of the Past 1000 Years, 23 CLIMATE RESEARCH 88, 105 (Jan. 31, 2003), http://www.int-res.com/articles/cr2003/23/c023p089.pdf. 117 Newsdesk, Smithsonian Statement: Dr. Wei-Hock (Willie) Soon, SMITHSONIAN (Feb. 26, 2015), http://newsdesk.si.edu/releases/smithsonian-statement-dr-wei-hock-willie-soon. 118 American Opinions on Global Warming: A Yale/Gallup/Clearvision Poll, Yale Program on Climate Change Communication (July 31, 2007), http://climatecommunication.yale.edu/publications/american-opinions-on-globalwarming. 119 IPCC, 2007: Summary for Policymakers, page 3 (emphasis in original), Climate Change 2007: The Physical Science Basis. Contribution of Working Group I to the Fourth Assessment Report of the Intergovernmental Panel on Climate Change (2007), https://www.ipcc.ch/pdf/assessment-report/ar4/wg1/ar4-wg1-spm.pdf. 120 Id. COMPLAINT 61