1 internal acknowledgement of the reality of climate change and its likely consequences. These 2 actions include, but are not limited to, making multi-billion-dollar infrastructure investments for 3 their own operations that acknowledge the reality of coming anthropogenic climate-related change. 4 These investments included (among others), raising offshore oil platforms to protect against sea 5 level rise; reinforcing offshore oil platforms to withstand increased wave strength and storm 6 severity; and developing and patenting designs for equipment intended to extract crude oil and/or 7 natural gas in areas previously unreachable because of the presence of polar ice sheets.123 144. 8 9 For example, in 1973 Exxon obtained a patent for a cargo ship capable of breaking through sea ice124 and for an oil tanker125 designed specifically for use in previously unreachable 10 areas of the Arctic. 11 145. In 1974, Chevron obtained a patent for a mobile arctic drilling platform designed 12 to withstand significant interference from lateral ice masses,126 allowing for drilling in areas with 13 increased ice floe movement due to elevated temperature. 146. 14 That same year, Texaco (Chevron) worked toward obtaining a patent for a method 15 and apparatus for reducing ice forces on a marine structure prone to being frozen in ice through 16 natural weather conditions,127 allowing for drilling in previously unreachable Arctic areas that 17 would become seasonally accessible. 18 147. Shell obtained a patent similar to Texaco’s (Chevron) in 1984.128 19 148. In 1989, Norske Shell, Royal Dutch Shell’s Norwegian subsidiary, altered designs 20 for a natural gas platform planned for construction in the North Sea to account for anticipated sea 21 22 23 24 25 26 27 28 SHER EDLING LLP 123 Amy Lieberman & Suzanne Rust, Big Oil braced for global warming while it fought regulations, L.A. TIMES (Dec. 31, 2015), http://graphics.latimes.com/oil-operations. 124 Patents, Icebreaking cargo vessel, Exxon Research Engineering Co. (Apr. 17, 1973), https://www.google.com/ patents/US3727571. 125 Patents, Tanker vessel, Exxon Research Engineering Co. (July 17, 1973), https://www.google.com/patents/ US3745960. 126 Patents, Arctic offshore platform, Chevron Research & Technology Co. (Aug. 27, 1974) https://www.google.com/ patents/US3831385. 127 Patents, Mobile, arctic drilling and production platform, Texaco Inc. (Feb. 26, 1974) https://www.google.com/ patents/US3793840. 128 Patents, Arctic offshore platform, Shell Oil Co. (Jan. 24, 1984) https://www.google.com/patents/US4427320. COMPLAINT 64