1 ARCO and ARAL brands; and by operating oil and gas extraction and refining projects in the Gulf 2 of Mexico, Alaska, Arkansas, Colorado, New Mexico, Oklahoma, Texas, and Wyoming. 3 BP America, Inc., is a wholly-owned subsidiary of BP P.L.C. that acts on 4 BP P.L.C.’s behalf and subject to BP P.L.C.’s control. BP America Inc. is a vertically integrated 5 energy and petrochemical company incorporated in the State of Delaware with its headquarters 6 and principal place of business in Houston, Texas. BP America, Inc., consists of numerous 7 divisions and affiliates in all aspects of the fossil fuel industry, including exploration for and 8 production of crude oil and natural gas; manufacture of petroleum products; and transportation, 9 marketing, and sale of crude oil, natural gas, and petroleum products. BP America Inc. was 10 formerly known as, did or does business as, and/or is the successor in liability to BP Products 11 North America Inc., Atlantic Richfield Company, BP Amoco Corporation, Amoco Corporation, 12 Amoco Oil Company, The American Oil Company, BP Exploration & Oil Inc., Sohio Oil 13 Company, Standard Oil of Ohio (SOHIO), Standard Oil (Indiana), BP Amoco Plc, BP Oil Inc., BP 14 Oil Company, Atlantic Richfield Delaware Corporation, Atlantic Richfield Company (a 15 Pennsylvania corporation), ARCO Products Company, and Arco Chemical Company, a division 16 of Atlantic Richfield Company. BP is also a major manufacturer and marketer of commodity 17 petrochemical products. BP America Inc. is registered to do business in the State of California and 18 has a registered agent for service of process with the California Secretary of State. 19 20 21 SHER EDLING LLP f. g. Defendants BP P.L.C. and BP America, Inc. are collectively referred to herein as “BP.” h. BP does substantial fossil fuel product-related business in California, and a 22 substantial portion of its fossil fuel products are extracted, refined, transported, traded, distributed, 23 marketed, and/or sold in California. Among other operations, BP operates 275 ARCO-licensed 24 and branded gas stations in California and more than 70 compressed natural gas and liquefied 25 natural gas fueling stations, provides natural gas used to power more than 6.9 million California 26 households, and distributes and markets petroleum-based lubricants marketed under the “Castrol” 27 brand name throughout the state. From 2000 to 2013, BP also owned and operated an oil refinery 28 in Carson, Los Angeles County, California. BP’s marketing and trading business maintains an COMPLAINT 12