1 2 consumption of such products. These alternatives could have included, among other measures: a. Accepting scientific evidence on the validity of anthropogenic climate 3 change and the damages it will cause people and communities, including 4 Plaintiff, and the environment. Mere acceptance of that information would 5 have altered the debate from whether to combat global warming to how to 6 combat it; and avoided much of the public confusion that has ensued over 7 nearly 30 years, since at least 1988; 8 b. Forthrightly communicating with Defendants’ shareholders, banks, 9 insurers, the public, regulators, and Plaintiff about the global warming and 10 ocean temperature increase hazards of Defendants’ fossil fuel products that 11 were known to Defendants, would have enabled those groups to make 12 material, informed decisions about whether and how to address climate 13 change vis-à-vis Defendants’ products; 14 c. Refraining from affirmative efforts, whether directly, through coalitions, or 15 through front groups, to distort public debate, and to cause many consumers 16 and business and political leaders to think the relevant science was far less 17 certain that it actually was; 18 d. Sharing their internal scientific research with the public, and with other 19 scientists and business leaders, so as to increase public understanding of the 20 scientific underpinnings of climate change and its relation to Defendants’ 21 fossil fuel products; 22 e. Supporting and encouraging policies to avoid dangerous climate change, 23 and demonstrating corporate leadership in addressing the challenges of 24 transitioning to a low-carbon economy; 25 f. Prioritizing alternative sources of energy through sustained investment 26 and research on renewable energy sources to replace dependence on 27 Defendants’ inherently hazardous fossil fuel products; 28 SHER EDLING LLP COMPLAINT 71