1 USA Inc. is registered to do business in the State of California and has designated an agent for 2 service of process in California. 3 b. 4 Total E&P USA Inc. controls and has controlled companywide decisions about the quantity and extent of fossil fuel production and sales, including those of its subsidiaries. 5 c. Total E&P USA Inc. controls and has controlled companywide decisions 6 related to climate change and greenhouse gas emissions from its fossil fuel products, including 7 those of its subsidiaries. 8 d. Total Specialties USA Inc., is a wholly owned subsidiary of Total S.A., 9 involved in the marketing and distribution of Total S.A.’s fossil fuel products. Total Specialties 10 USA Inc. is incorporated in the State of Delaware and headquartered in Houston, Texas. Total 11 Specialties USA Inc. is registered to do business in the State of California and has designated an 12 agent for service of process in California. Total Specialties USA Inc. does substantial fossil fuel 13 product-related business in California, and a substantial portion of its fossil fuel products are 14 extracted, refined, transported, traded, distributed, marketed, and/or sold in California. For 15 instance, Total Specialties USA Inc. maintains regular distributorship relationships with several 16 California distributors of Total fossil fuel products, including engine oils, lubricants, greases, and 17 industrial petroleum products. 18 19 30. Eni Entities a. Eni S.p.A. (“Eni”) is a vertically integrated, multinational energy company 20 focusing on petroleum and natural gas. Eni is incorporated in the Republic of Italy, with its 21 principal place of business in Rome, Italy. With its consolidated subsidiaries, Eni engages in the 22 exploration, development, and production of hydrocarbons; in the supply and marketing of gas, 23 liquid natural gas, and power; in the refining and marketing of petroleum products; in the 24 production and marketing of basic petrochemicals, plastics and elastomers; in commodity trading; 25 and in electricity marketing and generation. 26 27 b. Eni controls and has controlled companywide decisions about the quantity and extent of fossil fuel production and sales, including those of its subsidiaries. 28 SHER EDLING LLP COMPLAINT 17