a. 1 The first patent for enhanced oil recovery technology, a process by which 2 CO2 is captured and reinjected into oil deposits, was granted to an ARCO 3 (BP) subsidiary in 1952.138 This technology could have been further 4 developed as a carbon capture and sequestration technique; b. 5 Phillips Petroleum Company (ConocoPhillips) obtained a patent in 1966 for 6 a “Method for recovering a purified component from a gas” outlining a 7 process to remove carbon from natural gas and gasoline streams;139 and c. 8 In 1973, Shell patented a process to remove acidic gases, including CO2, from gaseous mixtures. 9 156. 10 Despite this knowledge, Defendants’ later forays into the alternative energy sector 11 were largely pretenses. For instance, in 2001, Chevron developed and shared a sophisticated 12 information management system to gather greenhouse gas emissions data from its explorations 13 and production to help regulate and set reduction goals.140 Beyond this technological breakthrough, 14 Chevron touted “profitable renewable energy” as part of its business plan for several years and 15 launched a 2010 advertising campaign promoting the company’s move towards renewable energy. 16 Despite all this, Chevron rolled back its renewable and alternative energy projects in 2014.141 157. 17 Similarly, ConocoPhillips’ 2012 Sustainable Development report declared 18 developing renewable energy a priority in keeping with their position on sustainable development 19 and climate change.142 Their 10-K filing from the same year told a different story: “As an 20 independent E&P company, we are solely focused on our core business of exploring for, 21 22 23 24 25 26 27 28 SHER EDLING LLP 138 James P. Meyer, Summary of Carbon Dioxide Enhanced Oil Recovery (CO2EOR) Injection Well Technology, American Petroleum Institute, at 1, http://www.api.org/~/media/Files/EHS/climate-change/Summary-carbondioxide-enhanced-oil-recovery-well-tech.pdf. 139 Patents, Method for recovering a purified component from a gas, Phillips Petroleum Co. (Jan. 11, 1966), https://www.google.com/patents/US3228874. 140 Chevron, Chevron Introduces New System to Manage Energy Use (press release) (Sept. 25, 2001), https://www.chevron.com/stories/chevron-introduces-new-system-to-manage-energy-use. 141 Benjamin Elgin, Chevron Dims the Lights on Green Power, BLOOMBERG (May 29, 2014), https://www.bloomberg.com/news/articles/2014-05-29/chevron-dims-the-lights-on-renewable-energy-projects. 142 ConocoPhillips, Sustainable Development (2013) http://www.conocophillips.com/sustainabledevelopment/Documents/2013.11.7%201200%20Our%20Approach%20Section%20Final.pdf. COMPLAINT 69