1 Science Team.” GCST developed a strategy to spend millions of dollars manufacturing climate 2 change uncertainty. Between 2000 and 2004, Exxon donated $110,000 to Milloy’s efforts and 3 another organization, the Free Enterprise Education Institute and $50,000 to the Free Enterprise 4 Action Institute, both registered to Milloy’s home address.121 137. 5 Defendants by and through their trade association memberships, worked directly, 6 and often in a deliberately obscured manner, to evade regulation of the emissions resulting from 7 use of their fossil fuel products. 138. 8 Defendants have funded dozens of think tanks, front groups, and dark money 9 foundations pushing climate change denial. These include the Competitive Enterprise Institute, the 10 Heartland Institute, Frontiers for Freedom, Committee for a Constructive Tomorrow, and Heritage 11 Foundation. From 1998 to 2014 Exxon spent almost $31 million funding numerous organizations 12 misrepresenting the scientific consensus that Defendants’ fossil fuel products were causing climate 13 change. Several Defendants have been linked to other groups that undermine the scientific basis 14 linking Defendants’ fossil fuel products to climate change, including the Frontiers of Freedom 15 Institute and the George C. Marshall Institute. 139. 16 Exxon acknowledged its own previous success in sowing uncertainty and slowing 17 mitigation through funding of climate denial groups. In its 2007 Corporate Citizenship Report, 18 Exxon declared: “In 2008, we will discontinue contributions to several public policy research 19 groups whose position on climate change could divert attention from the important discussion on 20 how the world will secure the energy required for economic growth in an environmentally 21 responsible manner.”122 Despite this pronouncement, Exxon remained financially associated with 22 several such groups after the report’s publication. 140. 23 Today, Defendants, including Exxon, Chevron, BP, Shell, and ConocoPhillips 24 publicly purport to accept the consensus embodied in the most recent IPCC reports, that global 25 warming is occurring, and that human activity has been the dominant cause of global warming and 26 Seth Shulman et al. Smoke, Mirrors & Hot Air: How ExxonMobil Uses Big Tobacco’s Tactics to Manufacture Uncertainty on Climate Science, Union of Concerned Scientists, 19 (Jan. 2007), http://www.ucsusa.org/sites/default/files/legacy/assets/documents/global_warming/exxon_report.pdf. 122 ExxonMobil, 2007 Corporate Citizenship Report (Dec. 31, 2007), http://www.documentcloud.org/ documents/2799777-ExxonMobil-2007-Corporate-Citizenship-Report.html. 121 27 28 SHER EDLING LLP COMPLAINT 62