1 Chemical Corporation, Phillips 66, Shell Chemical Company, and Total Petrochemicals & 2 Refining USA, Inc.13 d. 3 The Information Council for the Environment (ICE): ICE was formed 4 by coal companies and their allies, including Western Fuels Association and the National Coal 5 Association. Associated companies included at least Pittsburg and Midway Coal Mining 6 (Chevron),14 and Island Creek Coal Company (Occidental). e. 7 The Global Climate Coalition (GCC): GCC was an industry group formed 8 to oppose greenhouse gas emission reduction policies and the Kyoto Protocol. It was founded in 9 1989 shortly after the first Intergovernmental Panel on Climate Change meeting was held, and 10 disbanded in 2001. Founding members included the National Association of Manufacturers, the 11 Edison Electric Institute, and the United States Chamber of Commerce. The GCC’s early 12 individual corporate members included Amoco (BP), API, Chevron, Exxon, Shell Oil, Texaco 13 (Chevron) and Phillips Petroleum (ConocoPhillips). During its existence, other members and 14 funders included ARCO (BP), the National Mining Association, and the Western Fuels 15 Association. The coalition also operated for several years out of the National Association of 16 Manufacturers’ offices. 17 III. AGENCY 42. 18 At all times herein mentioned, each of the Defendants was the agent, servant, 19 partner, aider and abettor, co-conspirator, and/or joint venturer of each of the remaining 20 Defendants herein and was at all times operating and acting within the purpose and scope of said 21 agency, service, employment, partnership, conspiracy, and joint venture and rendered substantial 22 assistance and encouragement to the other Defendants, knowing that their conduct was wrongful 23 and/or constituted a breach of duty. 24 IV. 43. 25 26 JURISDICTION AND VENUE This court’s personal jurisdiction over Defendants named herein is proper because each Defendant maintains substantial contacts with California by and through its fossil fuel 27 28 SHER EDLING LLP 13 14 AFPM, Membership Directory, https://www.afpm.org/membership-directory (accessed Nov. 5, 2018). Hereinafter, parenthetical references to Defendants indicate corporate ancestry and/or affiliation. COMPLAINT 26