1 related climactic changes since the beginning of the Great Acceleration. At the same time, 2 however, Defendants continue to play up the uncertainty of future climate modeling, and the 3 purported historic uncertainty, imprecision, and inconsistency of climate science to disguise and 4 distract from their own knowledge and intensive research dating back to at least 1960s. While 5 Defendants claim to accept the scientific consensus on climate change, moreover, they still 6 continue to promote and expand their exploration, production, promotion, marketing, and sale of 7 fossil fuels that are the dominant cause of anthropogenic global warming. 8 141. 9 greenhouse gas emissions by, for example, delineating practical policy goals and regulatory 10 structures that would have allowed them to continue their business ventures while reducing 11 greenhouse gas emissions and supporting a transition to a lower carbon future. Instead, Defendants 12 undertook a momentous effort to evade international and national regulation of greenhouse gas 13 emissions to enable them to continue unabated fossil fuel production. 14 142. As a result of Defendants’ tortious, false and misleading conduct, reasonable 15 consumers of Defendants’ fossil fuel products, members of the public, and policy-makers, have 16 been deliberately and unnecessarily deceived about: the role of fossil fuel products in causing 17 ocean warming and consequent harmful algal blooms and domoic outbreaks; the acceleration of 18 global warming since the mid-20th century and the continuation thereof; and about the fact that 19 the continued increase in fossil fuel product consumption creates severe environmental threats and 20 significant economic costs for members of the ocean-dependent economy. Reasonable consumers 21 and policy makers have also been deceived about the depth and breadth of the state of the scientific 22 evidence on anthropogenic climate change, and in particular, on the strength of the scientific 23 consensus demonstrating the role of fossil fuels in causing climate change and its potentially 24 destructive impacts. 25 F. In Contrast to Their Public Statements, Defendants’ Internal Actions Demonstrate Their Awareness of and Intent to Profit from the Unabated Use of Fossil Fuel Products. 143. In contrast to their public-facing efforts challenging the validity of the scientific 26 27 28 SHER EDLING LLP Defendants could have contributed to the global effort to mitigate the impacts of consensus about anthropogenic climate change, Defendants’ acts and omissions evidence their COMPLAINT 63