d. 1 2 petrochemicals, such as polyvinyl chloride resins, is a wholly owned subsidiary of Occidental 3 Petroleum Corporation. Occidental Chemical Corporation is registered to do business in the State 4 of California and has designated an agent for service of process in the State of California. e. 5 6 Defendants Occidental Petroleum Corporation and Occidental Chemical Corporation are collectively referred to as “Occidental.” f. 7 Occidental does substantial fossil fuel product-related business in the State 8 of California, and a substantial portion of its fossil fuel products are extracted, refined, transported, 9 traded, distributed, marketed, and/or sold in California. For instance, Occidental has extracted and 10 transported its fossil fuel products from approximately 30,900 drilling locations within the San 11 Joaquin, Los Angeles, Ventura, and Sacramento Basins in California. 12 33. Repsol S.A. a. 13 Repsol S.A. (“Repsol”) is a vertically integrated, multinational global 14 energy company, incorporated in the Kingdom of Spain, with its principal place of business in 15 Madrid, Spain. Repsol is involved in multiple aspects of the fossil fuel industry, including 16 exploration, production, marketing, and trading. Repsol engages in significant fossil fuel 17 exploration and production activities in the United States, including in the Gulf of Mexico, the 18 Marcellus Shale in Pennsylvania, the Eagle Ford Shale in South Texas, the Mississippi Lime in 19 Oklahoma and Kansas, the North Slope in Alaska, and the Trenton-Black River in New York. 20 21 b. Repsol controls and has controlled companywide decisions about the quantity and extent of fossil fuel production and sales, including those of its subsidiaries. 22 c. Repsol controls and has controlled companywide decisions related to 23 climate change and greenhouse gas emissions from its fossil fuel products, including those of its 24 subsidiaries. 25 SHER EDLING LLP Occidental Chemical Corporation, a manufacturer and marketer of d. Repsol does substantial fossil fuel product-related business in the State of 26 California, and a substantial portion of its fossil fuel products are extracted, refined, transported, 27 traded, distributed, marketed, and/or sold in California. For instance, Repsol subsidiary Repsol 28 Energy North America Corporation, incorporated in the State of Texas and with its principal place COMPLAINT 20