d. 1 ConocoPhillips Company is a wholly owned subsidiary of ConocoPhilliips 2 that acts on ConocoPhillips’ behalf and subject to ConocoPhillips’ control. ConocoPhillips 3 Company is incorporated in Delaware and has its principal office in Bartlesville, Oklahoma. 4 ConocoPhillips Company is registered to do business in California and has a registered agent for 5 service of process in California. 6 e. Phillips 66 is a multinational energy and petrochemical company 7 incorporated in Delaware and with its principal place of business in Houston, Texas. It 8 encompasses downstream fossil fuel processing, refining, transport, and marketing segments that 9 were formerly owned and/or controlled by ConocoPhillips. Phillips 66 is registered to do business 10 in the State of California and has a registered agent for service of process in California. f. 11 Defendants ConocoPhillips, ConocoPhillips Company, and Phillips 66, and 12 their predecessors, successors, parents, subsidiaries, affiliates, and divisions are collectively 13 referred to herein as “ConocoPhillips.” g. 14 ConocoPhillips does substantial fossil fuel product-related business in 15 California, and a substantial portion of its fossil fuel products are extracted, refined, transported, 16 traded, distributed, marketed, and/or sold in California. For instance, ConocoPhillips owns and 17 operates oil and natural gas terminals in California, owns and operates refineries in Arroyo Grande 18 (San Luis Obispo County), Colton (San Bernardino County), and Wilmington (Los Angeles 19 County), California, and distributes its products throughout California. Phillips 66 also owns and 20 operates oil refineries in Rodeo (Contra Costa County), Santa Maria (Santa Barbara County), and 21 Wilmington (Los Angeles County), California, each of which was owned and operated by 22 ConocoPhillips and its predecessors in interest from 1997 to 2012. 23 24 29. Total Entities a. Total E&P USA Inc. is a wholly owned subsidiary of Total S.A.—a French 25 energy conglomerate—engaged in the North American segment of Total SA’s fossil fuel products- 26 related business. Total E&P USA Inc. and its subsidiaries are involved in the exploration for and 27 extraction, transportation, research, and marketing of Total S.A.’s fossil fuel products. Total E&P 28 SHER EDLING LLP COMPLAINT 16