1 the exploration, development, and production of oil, and natural gas. It is incorporated in the State 2 of Delaware and maintains its principal place of business in Oklahoma City, Oklahoma. Devon is 3 engaged in multiple aspects of the fossil fuel industry, including exploration, development, 4 production, and marketing of its fossil fuel products. b. 5 6 decisions about the quantity and extent of fossil fuel production and sales, including those of its 7 subsidiaries. c. 8 9 10 Devon Energy Corporation controls and has controlled companywide decisions related to climate change and greenhouse gas emissions from its fossil fuel products, including those of its subsidiaries. d. 11 Devon Energy Production Company, L.P., is a Devon subsidiary registered 12 to do business in the State of California and with a designated agent for service of process in 13 California. Devon Energy Production Company, L.P., does substantial fossil fuel product-related 14 business in California. e. 15 Devon Energy Corporation is a successor-in-interest to the Pauley 16 Petroleum Company (“Pauley”). At times relevant to this complaint, Pauley did substantial fossil- 17 fuel related business in California. Specifically, this included owning and operating a petroleum 18 refinery in Newhall (Los Angeles County), California, from 1959 to 1989, and a refinery in 19 Wilmington (Los Angeles County), California, from 1988 to 1992. Pauley merged with Hondo Oil 20 and Gas Co. (“Hondo”) in 1987. Subsequently, Devon Energy Corp. acquired Hondo in 1992. f. 21 22 23 24 SHER EDLING LLP Devon Energy Corporation controls and has controlled companywide Defendants Devon Energy Corporation and Devon Energy Production Company, L.P., are collectively referred to as “Devon.” 37. Encana Corporation a. Encana Corporation (“Encana”) is a Canadian corporation with its principal 25 place of business in Calgary, Alberta, Canada. Encana is an extractor and marketer of oil and 26 natural gas and has facilities including gas plants and gas wells in Colorado, Texas, Wyoming, 27 Louisiana, and New Mexico. By approximately 2005, Encana was the largest independent owner 28 and operator of natural gas storage facilities in North America. COMPLAINT 23