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office in Irvine, Orange County, California. BP maintains an energy research center in San Diego,
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San Diego County, California.
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Shell Entities
a.
Royal Dutch Shell PLC is a vertically integrated, multinational energy and
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petrochemical company. Royal Dutch Shell is incorporated in England and Wales, with its
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headquarters and principal place of business in the Hague, Netherlands. Royal Dutch Shell PLC
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consists of numerous divisions, subsidiaries and affiliates engaged in all aspects of the fossil fuel
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industry, including exploration, development, extraction, manufacturing and energy production,
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transport, trading, marketing and sales.
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b.
Royal Dutch Shell PLC controls and has controlled companywide decisions
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about the quantity and extent of fossil fuel production and sales, including those of its subsidiaries.
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Royal Dutch Shell PLC’s Board of Directors in the Hague determines whether and to what extent
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Shell subsidiary holdings around the globe produce Shell-branded fossil fuel products. For
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instance, Royal Dutch Shell PLC’s Board of Directors makes individual decisions on whether and
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when to initiate drilling in particular oil reserves.
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c.
Royal Dutch Shell PLC controls and has controlled companywide decisions
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related to climate change and greenhouse gas emissions from its fossil fuel products, including
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those of its subsidiaries. Overall accountability for climate change within the Shell group of
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companies lies with Royal Dutch Shell PLC’s Chief Executive Officer and Executive Committee.
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Additionally, Royal Dutch Shell PLC has directed its subsidiaries to reduce the carbon footprint
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of all fossil fuel products produced under the Shell brand, including those of its subsidiaries, and
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across all upstream and downstream segments of its operations.
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SHER
EDLING LLP
26.
d.
Shell Oil Products Company LLC is a wholly-owned subsidiary of Royal
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Dutch Shell PLC. Shell Oil Products Company LLC is incorporated in the State of Delaware and
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maintains its principal place of business in Houston, Texas. Shell Oil Products Company LLC is
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registered to do business in the State of California and has a registered agent for service of process
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in California. Shell Oil Products Company LLC is an energy and petrochemical company involved
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in refining, transportation, distribution and marketing of Shell fossil fuel products.
COMPLAINT
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