1 reasonably should have to mitigate or avoid those dire adverse impacts. Defendants instead 2 adopted the position, as described below, that the absence of meaningful regulations on the 3 consumption of their fossil fuel products was the equivalent of a social license to continue the 4 unfettered pursuit of profits from those products. This position was an abdication of Defendants’ 5 responsibility to consumers and the public, including Plaintiff, to act on their unique knowledge 6 of the reasonably foreseeable hazards of unabated production and consumption of their fossil fuel 7 products. 8 E. Defendants Did Not Disclose Known Harms Associated with the Extraction, Promotion, and Consumption of Their Fossil Fuel Products and Instead Affirmatively Acted to Obscure Those Harms and Engaged in a Concerted Campaign to Evade Regulation. 112. By 1988, Defendants had amassed a compelling body of knowledge about the role 9 10 11 12 of anthropogenic greenhouse gases, and specifically those emitted from the normal use of 13 Defendants’ fossil fuel products, in causing global warming, increased mean sea surface 14 temperature, marine heatwaves, harmful algal blooms, and the attendant consequences for human 15 communities and the environment. On notice that their products were causing global climate 16 change and dire effects on the planet, Defendants were faced with the decision of whether to take 17 steps to limit the damages their fossil fuel products were causing and would continue to cause for 18 virtually every one of Earth’s inhabitants, including Plaintiff. 19 Defendants at any time before or thereafter could and should reasonably have taken 20 any of a number of steps to mitigate the damages caused by their fossil fuel products, and their 21 own comments reveal an awareness of what some of these steps may have been. Defendants should 22 have made reasonable warnings to consumers, the public, and regulators of the dangers known to 23 them of the unabated consumption of their fossil fuel products, and they should have taken 24 reasonable steps to limit the potential greenhouse gas emissions arising out of those products. 25 SHER EDLING LLP 113. 114. But several key events during the period 1988–1992 appear to have prompted 26 Defendants to change their tactics from general research and internal discussion on climate change 27 to a public campaign aimed at evading regulation of their fossil fuel products and/or emissions 28 therefrom. These include: COMPLAINT 50